Other healthcare professionals in the pharmacy

Background

In many community pharmacies, it is becoming more common to see pharmacists and pharmacy technicians working alongside other regulated health professionals, including nurses, dietitians, and audiologists. While having these professionals work collaboratively within the pharmacy team can enhance patient care, it also adds complexity in terms of roles, responsibilities, and accountability.

The Standards for the Operation of Licensed Pharmacies (SOLP) provides requirements and responsibilities for licensees who have other regulated health professionals working as part of their pharmacy team.

The SOLP also differentiates between regulated health professionals who are integrated into the pharmacy team and those who practise independently in a shared premise co-located with the licensed pharmacy. This distinction is important because it determines whether the licensee is responsible for overseeing another professional’s practice.

Advice

When other regulated health professionals practice within the pharmacy, there are several practices for licensees to consider:

1. Oversight of practice and restricted activities.
   1. Restricted activities. When another regulated health professional is practising in the pharmacy, it is important for the licensee to understand what services these individuals are providing and whether they’re authorized to do so. There are restricted activities a pharmacy professional cannot perform, such as prescribing enteral nutrition or administering medication into a feeding tube; however, these activities may fall within the scope of practice of registered dieticians or nurses. The licensee oversees these activities by ensuring the other healthcare professionals have the required training and authorizations. Understanding each professional’s scope helps protect patients and allows the licensee to provide effective oversight.
   2. Policies and procedures. Having other types of health professionals working in the pharmacy adds complexity to the overall practice, with new services introducing potential risks. Policies and procedures need to reflect this broadening of the services provided in the pharmacy in order to outline roles, responsibilities, and expectations, and appropriately mitigate any risks. Consider activities such as documentation, retention of records, access and handling of controlled substances, performing point-of-care testing, and administration of medications. Essentially, any processes performed by other health professionals within the pharmacy should have clear policies and procedures documented.
   3. Collecting patient feedback and managing patient concerns. Ensure there are clear processes for when adverse events or patient concerns arise around other health professionals’ practice. Having clear expectations in place ensures that patients are protected and also supports the pharmacy team in handling tough situations effectively and in a person-centred manner.
   4. Continuous quality improvement. In accordance with the CQI+ program, when other health professionals are part of the pharmacy team, they will also be included in the pharmacy’s continuous quality improvement program. This includes them actively participating in the prevention and management of close calls and practice incidents that occur and contributing to a positive safety culture in the pharmacy.
2. Record keeping and documentation.
   1. Patient records. When another regulated health professional is practising in the pharmacy, the licensee should make sure that these professionals have clearly outlined role-based permissions and access within the pharmacy’s systems. This process supports the entire team with consistent and current access to shared patient records.
   2. Documentation. As members of a pharmacy team, other regulated health professionals are expected to document their work in a manner that is accessible to all team members and supports team-based care. The licensee is responsible for maintaining oversight of and managing all patient records created within the pharmacy, including those generated by other regulated health professionals. For example, if a registered nurse administers a vaccine within the pharmacy, their assessment, notes, or any other related patient information should be easily accessible to the rest of the pharmacy team. Integrating documentation ensures clarity and facilitates continuity of care for patients.
3. Alignment of practice.
   1. Resources. The same clinical tools, databases, and reference materials that the pharmacy team uses should be available to other regulated health professionals who are part of the pharmacy team to use when providing care to patients. They can use these resources when appropriate to provide evidence-based care to patients. Licensees should consider if any additional resources may be required to support the other regulated health professionals’ practice.
   2. Scope of practice. The involvement of other regulated health professionals within a pharmacy setting can expand the range of services available to patients, but these must align with and complement the pharmacist’s scope of practice. For example, an audiologist might perform an otoscopy and identify signs of excessive earwax (cerumen impaction) that could affect hearing. The pharmacist could then provide an appropriate over-the-counter product and counsel the patient on its safe use. Such collaboration enhances patient care and allows each professional to work to their full scope. Services that do not align with pharmacy practice should not be provided within the licensed pharmacy and may be better offered through a shared premises arrangement. An example of a service that is not aligned would be if a naturopath wanted to provide homeopathic treatments within the pharmacy. This would not be appropriate as these services do not meet the level of evidence required for pharmacy practice.
4. Shared premises.
   1. When share premises is appropriate. It is important to clearly distinguish between other health professionals who are part of the pharmacy team and those who are not. Under SOLP 2.11, if another regulated health professional is practising within the pharmacy, the licensee is responsible for ensuring their activities are integrated into pharmacy operations, supported by policies and procedures, and included in CQI+ processes. If these requirements cannot be met, then the professional is not part of the pharmacy team. Instead, they must practise independently as a shared premises arrangement. In this case, they operate as a completely separate business entity, with their own records, systems, and responsibilities. The licensee has no authority or accountability for their practice.
   2. Independence. In a shared premises arrangement, another regulated health professional has their own separate practice, usually adjacent to a pharmacy. An example of this is a physician’s office co-located with a pharmacy. While collaboration between these health professionals is still appropriate and encouraged, sharing of resources is not permitted. The following are characteristics that define a regulated health professional who requires their own separate practice:
      1. They maintain their own independent records that aren’t accessible to pharmacy staff.
      2. They deliver virtual care without any connection to the pharmacy’s practice.
      3. They use separate computer software, phone lines, or booking systems.
      4. Their practice runs independently, with no oversight from the licensee.
      5. They are not employees of the pharmacy.
   3. Lock and leave. If there are other healthcare professionals who practise independently in a shared premise, the licensee must ensure the pharmacy is secure. Lock and leave pharmacies prevent unauthorized access to patient information and drugs, which ensures the integrity of the licensed pharmacy space.

Further reading

• ACP resources
  • Lock and leave