To the Ministry of Health and OCP Board of Directors,

We, the registered pharmacists and physicians of Ontario, are formally petitioning for pharmacists to be able to perform therapeutic substitutions within the same therapeutic class. Currently, the lack of ability for pharmacists to perform a therapeutic substitution can lead to delays in therapy for patients (Ontario College of Pharmacists, 2024; O. Reg. 256/24, 2024). The inability to independently perform therapeutic substitutions also increases the administrative burden on pharmacists and physicians. A 2026 study found that  approximately 89% of surveyed pharmacists regularly consulted prescribers regarding therapeutic substitutions despite feeling competent to act independently (Nguyen et al., 2026). Furthermore, a separate study found that approximately 59% of physicians reported working overtime at least occasionally due to drug-shortage-related administrative demands, highlighting the strain on already stretched healthcare professionals (Jarrett et al., 2026).

A study of community pharmacies in Newfoundland found that prescription related interventions required an average of 9 minutes, with 18% of resolved interventions resulting in a different drug being dispensed (Young et al., 2012). A 2010 survey by the Canadian Pharmacists Association (CPhA) similarly found that drug shortages took an average of 30 minutes of a pharmacist’s shift (CPhA & CSHP, 2011). Drug shortages remain a persistent issue, with 2,588 new shortage reports submitted in Canada in 2024–2025 (Health Canada, 2026). Therefore, allowing pharmacists to perform therapeutic substitutions would streamline this process and would align Ontario with other provinces and territories. 

 Currently nine of thirteen Canadian provinces and territories permit some form of therapeutic substitution (McKesson Canada, 2024). Pharmacists in British Columbia, Saskatchewan, Quebec, and Newfoundland and Labrador may perform therapeutic substitutions within the same drug class, while New Brunswick, Nova Scotia, Prince Edward Island, and Yukon allow for therapeutic substitution with a medication that is clinically equivalent regardless of therapeutic class (BC Pharmacy Association, 2018; Government of Saskatchewan, 2025; Zhang & Tadrous, 2025). Alberta allows certain pharmacists to prescribe Schedule 1 drugs (Alberta College of Pharmacy, n.d.).

Manitoba has recently amended its legislation to permit pharmacists to perform therapeutic substitutions, bringing its scope more closely in line with jurisdictions like Nova Scotia (Hammerberg, 2026; Legislative Assembly of Manitoba, 2026). Ontario should follow suit, using British Columbia as a model for a smoother transition.

 Patient safety remains central to this proposal. Therapeutic substitution would therefore exclude medications with a narrow therapeutic index, controlled drugs, biologics, and other therapies where substitution could create significant clinical risk without appropriate context. Implementation could also require pharmacists to meet defined competency requirements, document the clinical rationale for substitution, notify the patient and prescriber where appropriate, and respect any request not to substitute. 

The current system can have meaningful consequences for patients when medication access is disrupted. In the CPhA survey, approximately 85% of Ontario pharmacist respondents reported that patients’ health outcomes were adversely affected by drug shortages, with pharmacists identifying consequences including additional travel to pharmacies, loss of trust, and patients stopping therapy (CPhA & CSHP, 2011). Thus, it is vital for pharmacists to be allowed to perform therapeutic substitutions within Ontario to tackle these growing concerns. 

References:

1. Ontario College of Pharmacists. (2024, October 1). Pharmacist prescribing: Initiating, adapting and renewing prescriptions guideline. https://ocpinfo.com/pharmacy-professionals/rules-and-standards-of-the-profession/practice-policies-guidelines/pharmacist-prescribing-initiating-adapting-and-renewing-prescriptions/
2. General, O. Reg. 256/24, under Pharmacy Act, 1991, S.O. 1991, c. 36 (2024). Ontario e-Laws. https://www.ontario.ca/laws/regulation/r24256
3. Nguyen, K. H. M., et al. (2026). Prescription modifications by pharmacists and their views on potential prescribing authority: A nationwide survey. International Journal of Pharmacy Practice. https://doi.org/10.1093/ijpp/riag031
4. Jarrett, J. B., Dillane, K. E., & Hollett, G. (2026). Treatment modifications after drug shortages among primary care physicians. JAMA Network Open, 9(1), e2552802. https://doi.org/10.1001/jamanetworkopen.2025.52802
5. Young, S. W., Bishop, L. D., & Conway, A. (2012). Interventions performed by community pharmacists in one Canadian province: A cross-sectional study. Therapeutics and Clinical Risk Management, 8, 415–421. https://doi.org/10.2147/TCRM.S37581
6. Canadian Pharmacists Association, & Canadian Society of Hospital Pharmacists. (2011, June). Canadian drug shortage monitoring system: Report of a survey of pharmacists.
7. McKesson Canada. (2024, November). Untapped opportunities in pharmacy: Expanding scope of practice and therapeutic substitutions. https://www.mckesson.ca/documents/265942/0/MCK_Untapped%2BOpportunities%2Bin%2BPharmacy_11-2024_EN%2B-%2BFINAL.pdf/599a71ac-a1e5-2612-3fe5-196c7592451f
8. BC Pharmacy Association. (2018, March 4). Adapting prescriptions: An increase in therapeutic substitutions by community pharmacists. https://www.bcpharmacy.ca/news/adapting-prescriptions-increase-therapeutic-substitutions-community-pharmacists
9. Government of Saskatchewan. (2025, August 19). New training for pharmacists to safely substitute medications. https://www.saskatchewan.ca/government/news-and-media/2025/august/19/new-training-for-pharmacists-to-safely-substitute-medications
10. Zhang, P. C., & Tadrous, M. (2025). Empowering pharmacists in Canada’s drug shortage response. Canadian Pharmacists Journal, 158(6), 341–343. https://doi.org/10.1177/17151635251365666
11. Alberta College of Pharmacy. (n.d.). Additional prescribing authorization (APA). https://abpharmacy.ca/regulated-members/registration/pharmacists/authorizations/additional-prescribing-authorization-apa/
12. Hammerberg, N. (2026, March 26). Friday five (March 27, 2026). College of Pharmacists of Manitoba. https://cphm.ca/friday-five/friday-five-march-27-2026/
13. Legislative Assembly of Manitoba. (2026). The Pharmaceutical Amendment, Regulated Health Professions Amendment and Public Health Amendment Act, S.M. 2026, c. 42. https://web2.gov.mb.ca/laws/statutes/2026/c04226.php
14. Health Canada. (2026, January 26). 2024–2025 review of drug shortages. Government of Canada. https://www.canada.ca/en/health-canada/services/drugs-health-products/drug-products/drug-shortages/2024-2025-review.html