ACP has received several inquiries recently about whether a pharmacist can refer to themselves as a “medical director.”
The term “medical director” is not a protected title under the Health Professions Act (HPA) and is not used, authorized, or directly regulated by ACP. Also, the duties, responsibilities, and scope of practice of a medical director are not defined and may be quite varied depending on the setting. However, the term “medical director” has traditionally been associated with medical practice by a physician. With this in mind, it is important to note that while practising and representing themselves as a pharmacist, pharmacists must ensure that they are not misleading the public or other regulated health professionals with the titles they use. In some settings, the term “medical director” enables certain privileges including ordering drugs outside of a pharmacy. Pharmacists are reminded that using the term “medical director” does not provide them with additional privileges that it may for a physician.
Section 102 of the HPA states: “A regulated member shall not engage in advertising that is untruthful, inaccurate or otherwise capable of misleading or misinforming the public.”
Depending on the context or setting that the title “medical director” is used, it is likely to cause a member of the public to believe that the medical director is a physician. Pharmacists and pharmacy technicians must make reasonable efforts to ensure they consistently hold themselves out in a manner that enables the public to understand who they are, and who they are not. At no point, should a member of the public, a pharmaceutical supply company, or another agency be led to believe that a pharmacist is granted additional privileges through the use of the term medical director beyond what they are provided under the existing legislative framework.
