Permanent closure

When a pharmacy permanently closes and the pharmacy licence is terminated, the pharmacy must cease to provide pharmacy services or otherwise engage in the practice of pharmacy. Once the pharmacy licence is terminated, the site is no longer licensed and therefore, may no longer store drugs or patient records. There are several time-sensitive and essential tasks that the licensee or temporary pharmacist in charge (TPIC) must perform to appropriately end pharmacy operations and to remain in compliance with section 27 of the Pharmacy and Drug Regulation and the Standards for the Operation of Licensed Pharmacies (SOLP).

1. Facilitate patient care

Prior to pharmacy closure, the licensee or TPIC must ensure patients are

• notified of the pharmacy closure,
• given the opportunity to obtain their prepared prescriptions prior to pharmacy closure, and
• able to access their records after the pharmacy has closed.

The licensee or TPIC must arrange to transfer patient records to another licensed pharmacy or give each patient access to a copy of their record to facilitate the continuity of patient care.

Notices to the public (using in-store postings and media announcements) should be made at least 30 days prior to pharmacy closure. Signage should be posted at the store entrance, and the pharmacy’s voicemail message should advise the public about the upcoming closure, including any information to assist the public with obtaining pharmacy services once the pharmacy has closed.

2. Manage and store pharmacy records

The licensee is designated as the custodian of patient health information under the Health Information Regulation and is responsible for maintaining patient records and protecting the confidentiality and security of the health information in their custody.

The licensee’s custodial duties cannot be relinquished and do not end upon the closure of the pharmacy. However, custodial duties can be transferred to another eligible custodian under the Health Information Regulation. For example, if the pharmacy records are transferred to another licensed pharmacy, the licensee of the pharmacy storing the records would become the custodian of the closed pharmacy’s records. A proprietor who is not a regulated member cannot become the custodian of patient records nor can they access the patient records.

When a pharmacy closes, the patient records must be stored at

1. another licensed pharmacy (the licensee of the pharmacy storing the records becomes the custodian); or
2. an ACP-approved secure location (the pharmacist who was the licensee of the closed pharmacy remains the custodian of the records), in which case,
   • the licensee must maintain the records in accordance with the Standards for the Operation of Licensed Pharmacies (SOLP);
   • only individuals who have been authorized by the licensee can access the records; and
   • custodial responsibilities continue until the life of the pharmacy records expire and the subsequent disposal of those records has been completed, as per the legislation.

3. Disposition of drugs

When a pharmacy closes, the licensee or TPIC must complete an inventory of all drugs in the pharmacy and prepare for disposition. A copy of the inventory must be

• maintained in the files of the closed pharmacy,
• sent to ACP, and
• kept by the licensee or TPIC.

There are a few options available to pharmacists regarding the disposition of drugs. The pharmacist may:

1. Destroy the drugs in a manner that complies with the Controlled Drugs and Substances Act and the Food and Drugs Act.
2. Return the drugs to the licensed dealer who sold or provided it, or to a licensed dealer who is licensed to destroy the drugs pursuant to a written order. 
3. Transfer the drug inventories to another pharmacist in good standing and who does not have a notice of restriction issued in their name by Health Canada. This practice is permitted as long as both pharmacists involved in the transaction take inventory of the drugs and keep a record of this inventory and of the transfer for a period of two years.
   • Both pharmacists should sign the record.
   • These records should be kept in an auditable format and made available to a Health Canada inspector upon request.
   • Pharmacists are responsible for the following:
     • Taking all reasonable steps that are necessary to protect the drug inventories that are under their control against loss or theft, including while the drugs are in transit between two pharmacies.
     • Notifying Health Canada after removing, transporting, or transferring a controlled substance from their place of business to any other place of business. Health Canada has developed a Pharmacy Closure Form for this transaction.
     • Reporting any loss or theft of controlled substances to Health Canada.

4. Notify ACP

When a pharmacy closes permanently, the licensee or TPIC must notify ACP immediately of the exact date of closure. 

Within five working days of the closure, the licensee or TPIC must complete the following steps:

1. Prepare your supporting documentation. All documentation must be in PDF format. The following written records are required:
   1. the inventory of all drugs in the pharmacy, and
   2. all narcotic and controlled drugs transferred from the pharmacy (if applicable).
2. Complete and submit your notification. This must be submitted by the licensee or TPIC.
   1. Access the notification of pharmacy closure (in myACP). It can be found in the Catalog.
   2. The notification will require you to upload the supporting documentation you prepared in step 1.

ACP will notify you if we have any questions regarding your notification. Once closed, the pharmacy licence is terminated and no pharmacy services may occur on the premises. ACP will update our records and notify Alberta Blue Cross of the pharmacy closure.

To assist with pharmacy closure, refer to the pharmacy closure plan.