Modernizing Canadian Pharmacists’ Scope of Practice for Controlled Drugs and Substances


Modernizing Canadian Pharmacists’ Scope of Practice for Controlled Drugs and Substances

Zahava R.S. Rosenberg-Yunger, MA, PhD i
Lisa D. Bishop, BScPharm, PharmD ii
Shelita Dattani, BScPharm, PharmD iii

Canadian Health Policy, June 2021. ISSN 2562-9492


Community pharmacies in Canada and globally were considered an essential service and remained open during the COVID-19 pandemic. Although pharmacists continued to provide medications to their patients, a gap was evident in their ability to ensure continuity of their patients’ opioid regimen in the absence of an active prescription or the inability to contact the prescriber. Recognizing this care gap, in March 2020 Health Canada issued a short-term subsection 56(1) class exemption under Health Canada’s Controlled Drugs and Substances Act (CDSA) and its Regulations authorizing pharmacists to independently manage controlled substances. This exemption is temporary and is due to expire on September 30, 2021. The four authorities of the CDSA exemptions permit pharmacists to extend prescriptions, transfer prescriptions to other pharmacists, receive verbal orders, and allow other pharmacy employees to deliver prescriptions of controlled substances to patients. A discussion about making the CDSA exemptions permanent are presented here. While these considerations are specific to the Canadian context, they have implications to similar healthcare systems considering optimizing pharmacists’ scope of practice in helping to address the opioid crisis.


i Adjunct Professor, Ted Rogers School of Management, Health Services Management, Ryerson University.
ii Associate Professor, School of Pharmacy, Memorial University of Newfoundland.
iii Vice-President, Pharmacy Affairs, Neighborhood Pharmacy Association of Canada.

SUBMISSION: May 19, 2021 | PUBLICATION: June 8, 2021

DISCLOSURE: Dr. Lisa Bishop received honoraria to present the findings of this research at national events and conferences (2020, 2021) and she also served as an expert witness to provide expert opinion evidence for fentanyl (2018). Dr. Rosenberg-Yunger was a consultant for the Canadian Pharmacists Association (CPhA) during the time the qualitative study was conducted. Dr. Shelita Dattani was a staff member at CPhA at the time the qualitative study was conducted and serves on the advisory board for EBSI (Emergent Biosolutions).