ACP’s Standards of Practice for Virtual Care (SPVC) have been in effect since January 2023. Since then, ACP’s pharmacy practice consultants (PPCs) have observed several regulated members who are not meeting the standards when providing virtual care to their patients. Following are some of the common issues noticed by the team.
Providing virtual care when not appropriate
Some pharmacy teams are referring their patients to pharmacists located in other pharmacies for virtual care assessments and plans over the telephone. Since the other pharmacists do not provide regular in-person care to these patients, this does not comply with Standard 3d(i) of the SPVC. This standard indicates that a regulated member must only provide a restricted activity using virtual care if the regulated member determines that virtual care will optimize and complement the in-person care a patient regularly receives from the regulated member.
When regulated members provide virtual care to patients who do not receive in-person care from them, regulated members must determine that the patient’s unique circumstances make in-person care impractical or impossible as outlined in Standards 3d(ii) and 3d(iii). Unique scenarios requiring virtual care must be assessed and documented by the pharmacist. In all circumstances, virtual care can only be provided if the pharmacist is able to complete a thorough assessment and manage the patient’s care appropriately using an enabling technology.
Inappropriate enabling technology
Some pharmacy teams are using enabling technologies, such as video communications software or booking software, that are not included in their privacy impact assessment (PIA) submitted to Office of the Information and Privacy Commissioner (OIPC). In addition, licensees often defer considerations of security and safety of patient information to the software provider. Completion of a PIA is a requirement of Standard 20 of the SPVC and discussion with OIPC helps the licensee ensure the security and the safety of patient information as per the Health Information Act and the Standards for the Operation of Licensed Pharmacies (SOLP).
Absence of policies and procedures for virtual care
Like other services provided by pharmacy teams, comprehensive policies and procedures must be developed and used for virtual care services. Many pharmacy teams are still unaware that the telephone can be considered virtual care in certain circumstances (this Link article from November 2022 can help!), which must be documented in their policies and procedures. For example, when a pharmacist uses the telephone (or another enabling technology that has been accepted in the PIA for the pharmacy) to assess a patient in another location to dispense or prescribe medication or provide a clinical follow up, this would be considered providing virtual care.
Documentation of the virtual care being provided by the pharmacy team must comply with the SPVC and Standard 18 and Appendix A of the Standards of Practice for Pharmacists and Pharmacy Technicians. Documentation of the virtual care provided must include the information outlined in Standards 11 and 12 of the SPVC, including, but not limited to
- the informed consent of the patient;
- the date, time, and enabling technology used to provide the virtual care; and
- that the regulated member and patient are identified.
Regulated members should regularly review the SPVC to ensure their virtual care practice complies with the standards.