BC Pharmacy Association makes five recommendations on medication incident reporting

The BC Pharmacy Association recently provided a submission to the College of Pharmacists of British Columbia on the implementation of mandatory medication incident reporting. 

The College stated in a message to members in The Tablet in February that it aims to make significant progress to implement Mandatory Anonymous Medication Incident Reporting (MIR) in 2024. Previously, the College’s board approved the idea in 2019. 

The Association is making five recommendations to address concerns of maintaining anonymity, to ensure pharmacies have time to implement the new mandatory reporting, and that individual pharmacies should maintain some flexibility on how each pharmacy complies with the program. 

MIR is expected require the anonymous logging and tracking of medication dispensing errors by pharmacy registrants, likely with the information sent to an independent third-party organization, followed by analysis performed on the data to identify trends and patterns. 

The BCPhA’s submission and its recommendations was filed to the College on Jan. 12, 2024. The Association made the following recommendations:

1. The College should enact bylaws to ensure that information collected into the Medication Incident Management system used by a pharmacy cannot lawfully be accessed and used by the College in any College proceeding arising from or related to the incident.
2. We recommend providing registrants with a timeframe of at least 18 months from the time that the standards are approved by the College Board. This will allow registrants to budget for, purchase and implement software/procedures, and socialize and train staff on the new standards.
3. We recommend that the College provide as much flexibility as possible when it comes to pharmacies selecting their platform for MIR to National Incident Data Repository for Community Pharmacies. Pharmacies should be permitted to use any of the existing commercial MIR platforms, as well as be permitted to develop their own reporting platforms as long as they meet the provincial requirements.
4. Pharmacies should have flexibility to choose how they conduct their Medication Safety Self-Assessments (MSSA). We recommend that the College set the minimum standards for what domains an MSSA must review, but let pharmacies determine how best to complete the assessment, whether that is through a commercial product (e.g. ISMP or Pharmapod) or an in-house developed process.
5. The College should also avoid being too prescriptive regarding the frequency of Continuous Quality Improvement (CQI) meetings and routine review of medication incidents. Most jurisdictions guidelines suggest annual or bi-annual CQI meetings and minimum quarterly review meetings. We also recommend the College develop guidance or toolkits to support pharmacies in meeting College expectations when conducting a CQI meeting and/or medication incident reviews, to ensure there is no gap between the College’s expectations and registrants’ understanding of their obligations. 

To read the full submission and list of recommendations, please visit bcpharmacy.ca/advocacy/submissions