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Mail order pharmacy services and compliance with new standards

November 2, 2022
All pharmacy teams must comply with the Standards of Practice for Virtual Care and ensure appropriate licensing.

ACP Council approved the Standards of Practice for Virtual Care (SPVC) in June 2022. The SPVC reflect the understanding that the ability of regulated members to routinely engage with patients in person is fundamental to the practice of pharmacy.

In-person care means the regulated member provides professional services to the patient from a licensed pharmacy, institution pharmacy, or other practice site located within Alberta. In-person care supports the establishment and maintenance of professional relationships and helps to ensure comprehensive assessment.

Regulated members who routinely engage and assess their patients in person may, on occasion and when appropriate, provide virtual care and deliver medications to their patients. In all encounters, regulated members must engage in patient assessment activities, apply processes to maintain patient confidentiality, and adhere to record-keeping and drug security requirements as specified in the Standards of Practice for Pharmacists and Pharmacy Technicians (SPPPT) and the Standards for the Operation of Licensed Pharmacies (SOLP). These practices do not require a mail order pharmacy licence.

There are unique circumstances that may make receiving regular, in-person care from a regulated member impractical or impossible. The limited number of instances where these circumstances are likely to occur are outlined in Standards 3(d)ii and 3(d)iii of the SPVC. These circumstances include

  • patients in remote and underserviced areas,
  • patients with health circumstances that prevent them from attending in-person for care,
  • patients in institutional settings, and
  • patients with limited psychosocial supports or economic means.

Mail order pharmacy licence

In order to provide restricted activities, including the dispensing and selling of drugs, to patients they do not see regularly in person, regulated members practising at licensed pharmacies must

  • ensure the pharmacy holds a mail order pharmacy licence, and
  • only provide restricted activities to serve a patient with circumstances that meet the criteria listed in Standards 3(d)ii and 3(d)iii of the SPVC.

Even if a pharmacy holds a mail order pharmacy licence, the pharmacy may not offer, advertise, or incentivize mail order pharmacy services based on determinations of efficiency or convenience.

It is important to note that community pharmacies with mail order licences are not exempt from complying with the SPVC or the SPPPT. Community pharmacies with mail order licences must review and, if necessary, adjust their policies and procedures to ensure compliance with the SPVC. These pharmacies must ensure patients receiving mail order services receive the same level of care that meets all the standards of practice as those patients who receive in-person care.

When do the standards take effect?

The SPVC take effect immediately for regulated members who work for any newly licensed pharmacy that opens between June 24, 2022, and January 15, 2023. As of January 16, 2023, all regulated members at all pharmacies and practice sites will be expected to comply with the Standards when providing virtual care to their patients. All licensees of licensed pharmacies who currently hold a mail order licence have been provided information to support understanding their responsibilities for ensuring their pharmacy practices will comply with the SPVC by January.

Regulated members must review and reflect on their pharmacy practices and professional relationships with all patients to ensure they comply with all standards and the Code of Ethics, regardless of practice setting or model of operations. If you practice in a licensed community pharmacy and determine that you are providing pharmacy services that are inconsistent with the licensure categories at your pharmacy, you must work with your licensee to make changes to ensure compliance. If additional support is required, you might consider contacting ACP at