Neighbourhood Pharmacies has submitted feedback to the Ontario College of Pharmacists regarding proposed learning requirements for the assessment and prescribing activities for minor ailments of acute pharyngitis, otitis externa and herpes zoster, as well as the injection of extended-release buprenorphine. Our submission calls for a modern, outcomes-focused regulatory approach that supports patient access to care while maintaining public safety.
Key recommendations include:
- Reconsider labelling these activities “higher-risk”, given that pharmacists already perform similar assessment, prescribing, monitoring, and referral functions safely within existing scope.
- Avoid introducing condition-specific competency declarations where pharmacists are already professionally and ethically required to practise within their competence and maintain ongoing proficiency.
- Adopt flexible, principles-based regulatory frameworks that focus on outcomes and accountability rather than activity-specific administrative requirements, ensuring regulation can adapt as pharmacy practice continues to evolve.
- Use product-neutral language in regulatory requirements to avoid unnecessary complexity and maintain flexibility as new therapies enter the market.
As pharmacy scope expands to meet growing healthcare needs, regulatory frameworks should remain proportionate, evidence-based, and future-ready—supporting innovation, patient access, and public confidence while preserving the strong accountability mechanisms already in place for pharmacists.