To:
Members of the Legislative Assembly of Alberta
Alberta Health
Alberta Blue Cross
All decision-makers responsible for Alberta’s pharmacy funding framework

Re: Alberta Pharmacy Funding Framework — Concerns Regarding Patient Access, Clinical Care, and System Impact

We are community pharmacists practicing across Alberta. We are writing directly, as independent practitioners, because we believe the current pharmacy funding framework raises serious concerns that go beyond pharmacy economics. These are concerns about patient access, continuity of care, timely treatment, and the long-term sustainability of front-line healthcare in Alberta.

Many Albertans already struggle to see a family doctor in a timely manner. For these patients, community pharmacies are often the fastest and most accessible point of care. When pharmacy services are restricted, delayed, or made financially unsustainable, patients may miss medication doses, delay treatment, experience worsening symptoms, or seek help from walk-in clinics, urgent care centres, or emergency departments.

Community pharmacists are especially important for seniors, rural residents, patients without timely access to a family doctor, and patients needing urgent help with medication issues, renewals, injections, minor conditions, or chronic disease support. The COVID-19 pandemic also showed the public value of community pharmacies as accessible healthcare sites that supported medication continuity, patient education, and vaccine delivery.

We are not opposed to cost control or accountability. We support the responsible use of public funds. We also recognize that measures such as clinical service caps and stronger oversight may help address inappropriate billing by a minority of providers when they are designed fairly.

However, we are concerned that elements of the current framework, as designed, may restrict appropriate clinical care, create unpaid professional obligations, reduce timely access for patients, and shift patients toward more expensive and already strained parts of the healthcare system. That outcome would cost Albertans more, not less.

We ask that decision-makers review the specific concerns below and work directly with frontline pharmacists to refine this framework before it harms the patients it is intended to serve.

 
1. Prescription Renewal Fees Should Not Be Capped in a Way That Discourages Timely Care
Prescription renewals are not administrative refill extensions. When a pharmacist renews a prescription, they must assess the patient, evaluate the appropriateness of continued therapy, identify safety concerns, document the clinical decision, and accept professional responsibility for that renewal.

For many Albertans who cannot see a family doctor in a timely manner, a pharmacist may be the only accessible healthcare professional available for a routine renewal. If renewal services are capped or inadequately recognized, pharmacists may be unable to sustain timely renewal services. Patients would then be redirected to family doctors, walk-in clinics, urgent care centres, or emergency departments for renewals that could often be safely managed at the pharmacy.

The result may be delayed refills, interrupted therapy, worsening chronic conditions, longer wait times, more pressure on physicians, and higher system costs. Renewal funding should support timely patient access while continuing to require proper clinical assessment, documentation, and accountability.

 
2. APA Prescribing Assessments Require Separate and Fair Recognition
Additional Prescribing Authority assessments represent a different category of clinical service. They involve patient assessment, clinical decision-making, prescribing responsibility, documentation, follow-up, and professional liability. They should not be treated the same as general clinical services within a shared cap.

If APA prescribing assessments are included within a general clinical services cap, pharmacists may be asked to assess, prescribe, document, and accept liability for a service without fair compensation once the cap is reached. In that situation, many pharmacists may reasonably be unable to continue providing the service.

The consequence is predictable: patients who cannot access a physician quickly may be redirected to walk-in clinics, urgent care centres, or emergency departments for conditions that could have been safely and efficiently assessed at the pharmacy.

We ask that APA prescribing assessments either be excluded from the general clinical services cap or placed under a separate APA-specific cap that reflects the expanded scope and liability involved. We also ask that the initial APA assessment fee be reviewed and increased to $30 to $35 to better reflect the clinical judgment, patient assessment, prescribing decision, documentation, liability, and required follow-up involved.

 
3. Valid Clinical Services Should Not Become Unpaid Professional Work After the Cap Is Reached
If a pharmacist reaches the clinical services cap, the framework should not create an expectation that they continue providing clinically valid, properly documented services without compensation or a fair alternative.

A service that is within the pharmacist’s scope of practice, clinically indicated, and appropriately documented has professional value. It requires patient assessment, clinical judgment, time, documentation, professional responsibility, and liability exposure.

If the government chooses not to reimburse a valid service after the cap is reached, the framework should not also create a situation where the pharmacist is expected to provide that service for free. This is not a reasonable professional standard.

In practice, this may discourage pharmacists from providing otherwise appropriate services after reaching the cap. Patients may then be redirected to family doctors, walk-in clinics, urgent care centres, or emergency departments, even when the issue could have been safely managed in the pharmacy.

This is especially harmful for patients who already cannot see their doctor in a timely manner. It may lead to delayed refills, delayed treatment, interrupted therapy, poorer outcomes, and more pressure on the broader healthcare system.

We ask that the framework include reasonable exceptions for clinically necessary services, transparent alternative pathways where appropriate, or a cap design that does not reduce legitimate patient care to unpaid professional labour.

 
4. Clinically Distinct Same-Day Services Should Be Recognized When Appropriate
A clinical services cap already creates a financial ceiling on overall spending. Adding further restrictions on separate services performed on the same day compounds the effect and may discourage complete patient care within a single visit.

Patients do not present with only one need at a time. A patient who comes in for an injection may also require a separate clinical assessment that appropriately leads to prescribing. These are distinct services with different clinical responsibilities, documentation requirements, and patient outcomes.

If pharmacists are only recognized for one service despite providing multiple clinically necessary services, the system may unintentionally encourage fragmented care. Patients may be asked to return another day, seek care elsewhere, or be referred to a clinic or emergency department for a concern that could have been safely managed during the same pharmacy encounter.

We ask that the framework allow payment for multiple services on the same day when each service is clinically distinct, separately documented, appropriate, and not duplicative. Cost control should target inappropriate duplication, not legitimate care delivered efficiently in a single patient encounter.

 
5. The 84/100-Day Dispensing Framework Should Preserve Clinical Judgment
We recognize that longer supply dispensing may be appropriate and convenient for stable patients. However, the 84/100-day dispensing framework should not be applied rigidly to all patients or all medications.

Many patients require shorter intervals for valid clinical reasons, including safety monitoring, recent therapy changes, adherence concerns, side-effect management, dose adjustments, high-risk medications, mental health stability, or substance-use considerations.

For patients without timely access to a physician, the pharmacist may be the only healthcare professional positioned to identify these concerns before harm occurs. A fixed dispensing model should not override individualized care or pressure pharmacists to provide longer supplies when shorter intervals are clinically safer.

We ask that the framework preserve pharmacist clinical judgment in determining appropriate supply intervals based on individual patient circumstances.

 
6. Dispensing Fees Must Reflect Inflation and Real Operating Costs
Alberta’s dispensing fee has remained near $12.15 since 2018. Adjusted for general inflation alone, that equivalent purchasing power would require a fee of approximately $15.00 to $15.50 today. This estimate does not account for pharmacy-specific cost pressures, including professional staffing, rent, utilities, insurance, software, regulatory compliance, inventory management, drug shortages, and the significant volume of undocumented clinical advice provided to patients daily.

Community pharmacies are not simply medication dispensaries. They are front-line healthcare access points. If dispensing fees do not keep pace with the real cost of operating a pharmacy, pharmacies may be forced to reduce hours, reduce staffing, reduce services, or exit the market entirely.

In rural and underserved communities, the loss of even one pharmacy creates an immediate and serious healthcare gap. Patients may be forced to travel farther, wait longer, interrupt therapy, or rely on already strained clinics, urgent care centres, and emergency departments.

The downstream cost to the healthcare system may exceed what would have been required to support a financially sustainable pharmacy network.

We ask that dispensing fees be meaningfully increased to reflect inflation and real operating costs, and that a built-in inflation adjustment mechanism be introduced for future fee reviews.

 
What We Are Asking
We respectfully ask decision-makers to review the framework with the following changes:

• Ensure prescription renewal fees fairly reflect the clinical responsibility, patient assessment, documentation, and liability involved.
• Exclude APA prescribing assessments from the general clinical services cap, or create a separate APA-specific cap that reflects expanded scope and professional responsibility.
  Increase the initial APA assessment fee to $30 to $35.
• Ensure valid, documented clinical services do not become unpaid professional work after the cap is reached.
• Create clear exceptions or alternative pathways for clinically necessary services when the cap has been reached.
• Allow payment for multiple same-day services when each is clinically distinct, separately documented, appropriate, and not duplicative.
• Ensure the 84/100-day dispensing framework remains clinically flexible and does not override pharmacist judgment.
• Use targeted auditing, documentation review, data analysis, and investigation to address inappropriate billing rather than broad restrictions that penalize all pharmacists.
• Engage frontline pharmacists directly in identifying cost-saving measures that reduce waste without reducing timely patient access.
• Protect access to pharmacist care, particularly for patients without timely physician access, rural residents, seniors, underserved communities, and high-risk patients.
• Increase dispensing fees meaningfully to reflect inflation and real pharmacy operating costs.
  Build an ongoing inflation-adjustment mechanism into future dispensing fee reviews.
• We are raising these concerns as practitioners who witness the impact of these decisions at the patient level every day. We are not asking for immunity from accountability. We are asking for a framework that is clinically sound, professionally fair, financially realistic, and genuinely designed to protect the patients it is intended to serve.

Cost control should not rely on blunt restrictions that reduce timely care, delay refills, weaken clinical judgment, create unpaid professional work, or shift patients into more expensive parts of the healthcare system.

If the goal is to reduce unnecessary costs, frontline pharmacists should be part of that discussion. Pharmacists understand where waste, duplication, inappropriate billing, and avoidable costs occur in daily practice. They can help identify practical solutions that protect taxpayers without reducing patient access.

Community pharmacies are part of Alberta’s healthcare solution. A fair funding framework should protect patient access, support appropriate clinical care, reflect real-world operating costs, and reduce pressure on the broader healthcare system, not add to it.

We are prepared to participate in any consultation process and welcome the opportunity to provide frontline perspective on this issue.

Respectfully submitted,

Alberta Community Pharmacists