Government submissions archive
August 2020
Federal Pre-Budget Consultation
CPhA submitted a brief to the federal pre-budget consultation highlighting our recommendations for the 2021 budget. These include ensuring that Canada is prepared for the upcoming flu season amidst the global COVID-19 pandemic, with the goal of increasing vaccination rates and ensuring the safety of patients and health care workers; improving access to and coverage for health care services for First Nations, Métis and Inuit patients; and supporting advances in pharmacy practice that have resulted from the COVID-19 pandemic in order to achieve long-term improvements to patient care in Canada.
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March 2020
Letter to First Ministers on COVID-19 and the risk to Canada’s drug supply
CPhA sent a letter to First Ministers ahead of their meeting in Ottawa to discuss the evolving COVID-19 pandemic to highlight our concerns regarding Canada’s fragile drug supply, stockpiling of medications and ensuring pharmacists have the appropriate protections and resources in the face of a pandemic.
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September 2019
Consultation on the Potential Market for Cannabis Health Products
CPhA’s submission in response to Health Canada’s consultation on the potential market for Cannabis Health Products (CHPs) includes our view that a pathway to market for CHPs is necessary considering the growing public interest in these products, currently being sourced by the illegal market. CPhA believes that cannabis-based products that make health claims supported by evidence have no place in the recreational drug retail market or anywhere that patients cannot seek expert guidance from health care providers.
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June 2019
Consultation on Regulatory Changes for Tramadol
CPhA submitted a brief in response to Health Canada’s proposed regulatory changes to include tramadol to Schedule I to the Controlled Drugs and Substances Act (CDSA) and to the Schedule to the Narcotic Control Regulations (NCR). Within the submission CPhA expresses support for these amendments, which align with recommendations CPhA has made previously in its May 2018 position statement on tramadol and response to the tramadol consultation of August 2018. CPhA also repeats recommendations that Health Canada undertake a critical review of the clinical evidence in support of combination opioid analgesics and that pharmacists be included as “practitioners” within the CDSA so that they may expand their role in the management and oversight of opioid therapy.
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May 2019
Consultation to amend the Narcotic Control Regulations (NCR), the Benzodiazepines and Other Targeted Substances Regulations (BOTSR) and the Food and Drug Regulations-Part G (FDR — Part G)
CPhA submitted a brief in response to Health Canada’s consultation to modernize the NCR, BOTSR and FDR-Part G to better support modern pharmacy practices and address gaps and inconsistencies. CPhA’s submission includes our recommendation that pharmacists be added to the CDSA list of “practitioners” to improve monitoring and intervention of inappropriate prescribing and dispensing practices as well as others that attempt to bring the regulations in line with evolving pharmacy technologies, drug distribution, business practices and the full scope of pharmacy technicians.
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February 2019
Consultation on the Strict Regulation of Edible Cannabis, Extracts and Topicals
CPhA submitted a brief in response to Health Canada’s consultation on the strict regulation of edible cannabis, extracts and topicals. The submission outlines CPhA’s general support for the proposed amendments that focus on public protection and quality-controlled production of these forms of cannabis edibles, extracts and topicals. CPhA further recommends that Health Canada consider a separate regulatory stream for cannabis edibles, extracts and topicals intended for medical use; that it take a first step in allowing pharmacists to help patients manage their cannabis therapy by enabling the purchase of CBD products through pharmacies; and that Health Canada expand public education about the risks associated with cannabis edibles, with special consideration given to seniors.
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January 2019
Draft - Drug and natural health products recall guide consultation
CPhA submitted a brief to Health Canada’s consultation on the Draft - Drug and natural health products recall guide. Within the submission, CPhA commends Health Canada for developing the guidelines. We also offer a number of recommendations to support pharmacists, who are on the frontlines of drug recalls as intermediaries between patients and the drug distribution system. These recommendations centre on the provision of consistent, comprehensive and timely messaging and procedures, as well as support and compensation to pharmacists for recall processes and clinical services, such as therapeutic substitution, which provide patients with individualized care both during and beyond instances of drug supply challenges.
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September 2018
Pharmacare consultation
CPhA submitted a brief to the national pharmacare consultation that aligns with CPhA’s PharmAccord position and addresses the key principles of access, coverage, equity, sustainability and quality. We believe these principles can be best attained by building on the existing mix of public and private coverage and leveraging the strengths of both systems to achieve complete and sustainable drug access. Key pillars of this approach include the implementation of a comprehensive minimum national formulary, uniform catastrophic drug coverage across Canada, and medication management support services by pharmacists to ensure the safety, effectiveness and value of drug therapy.
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August 2018
Tramadol consultation
CPhA submitted a brief in response to Health Canada’s proposal to add tramadol to Schedule I of the Controlled Drugs and Substances Act and the Schedule to the Narcotic Control Regulations. Within the submission, CPhA commends Health Canada for the decision to reschedule tramadol as a controlled narcotic. We further recommend that Health Canada conduct a critical review of the clinical evidence in support of combination opioid analgesics and that it make changes to the CDSA that would allow pharmacists to play a greater role in the management of their patients’ opioid therapies.
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August 2018
Federal Pre-Budget Consultation
CPhA submitted a brief to the federal pre-budget consultation highlighting three recommendations for the 2019 federal budget, including: a federal investment to harmonize catastrophic drug coverage across Canada, a commitment to regulate the price of medical cannabis as it does other prescription drugs, which are not taxed, and an investment of $1M/year for 5 years to support an awareness raising campaign for pharmacist-led medication return programs.
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July 2018
Consultation on the restriction of marketing and advertising of opioids
CPhA submitted a brief in response to Health Canada’s Notice of Intent to Restrict the Marketing and Advertising of Opioids. In recognition of the evidence that demonstrates how opioid marketing can influence prescribing decisions, our submission presents CPhA’s general support for further restrictions on the marketing and advertising of opioids. The submission further underscores the significance of inappropriate opioid prescribing and recommends changes to the Controlled Drugs and Substances Act (CDSA) to include pharmacists in the definition of “prescriber.” This change would authorize and empower pharmacists to, where appropriate, reduce the dosage of opioids for patients; administer a patient’s opioid tapering plan; or recommend and prescribe alternative therapies to opioids for the benefit and safety of patients.
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June 2018
Proposed pathogens of interest list – Health Canada consultation
CPhA submitted a brief in response to Health Canada’s proposed Pathogens of Interest List to inform sponsors of the bacterial pathogens in most urgent need of innovative drugs and/or devices and guide the development of new tools and policy approaches. Within the submission, CPhA expresses support for this initiative and the pathogens included in the list. However, we also recommend that more can be done on the frontlines of primary care, where there are few formal antimicrobial stewardship programs in place, to enhance pharmacists’ role in addressing antimicrobial resistance and ensuring appropriate antimicrobial use.
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January 2018
Proposed approach to the regulation of cannabis – Health Canada consultation
CPhA submitted a brief in response to Health Canada’s proposed approach to the regulation of cannabis. The submission underscores CPhA’s position that medical cannabis users should be supported and protected in the medical stream, through appropriate access, affordability and clinical oversight by pharmacists, once recreational cannabis is legal. CPhA further recommends that any cannabis product making a health claim should be available for sale exclusively in pharmacies, and that their placement within a pharmacy should be assessed on a case-by-case basis with regard to safety, and the potential for abuse and diversion.
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November 2017
Availability of non-prescription low-dose codeine products – Health Canada consultation
CPhA submitted a brief in response to Health Canada’s proposed amendments to the Narcotic Control Regulations under the Controlled Drugs and Substances Act, which would require that all products containing codeine be sold by prescription only. The CPhA submission expresses our support for this regulation change and proposes recommendations that pharmacists be provided with greater access to appropriate monitoring tools and the designation of pharmacists as practitioners under the CDSA.
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August 2017
Cannabis Legalization – Standing Committee on Health
CPhA submitted a brief expressing its views on Bill C-45: An Act respecting cannabis and to amend the Controlled Drugs and Substances Act, the Criminal Code and other Acts. The CPhA submission underscores our existing position that two different streams of cannabis – medical and recreational – must be maintained once cannabis is legalized in 2018. We have also expressed our concerns about how the legislation would impact the current medical cannabis regime and how regulations should provide greater support for patients who use cannabis for medical purposes, notably, through pharmacist dispensing and managing of medical cannabis.
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August 2017
Federal Pre-Budget Consultation
CPhA submitted a brief to the federal pre-budget consultation highlighting four recommendations for the 2018 federal budget, including: federal investment to equalize naloxone access across the country, federal funding to harmonize catastrophic drug coverage in Canada, investment in health science and practice-based research, and equitable access to health services for Indigenous drug plan beneficiaries.
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June 2017
Antimicrobial Resistance – Standing Committee on Health
Shelita Dattani, Director, Practice Development and Knowledge Translation, appeared before the Standing Committee on Health as part of its study on antimicrobial resistance to highlight the key role pharmacists can play as antimicrobial stewards.
Read the speaking notes
November 2016
Letter to Minister of Health on Codeine/Prescribing Rights
CPhA sent a letter to Jane Philpott, Minister of Health, outlining its policy statement on codeine products. The letter calls for all codeine products to be available by prescription only and emphasizes the need to designate pharmacists as practitioners under the Controlled Drugs and Substances Act to help combat the opioid crisis in Canada.
Read the letter
October 2016
Opioid Crisis in Canada — Standing Committee on Health
Alistair Bursey, Chair, and Phil Emberley, Director of Professional Affairs, appeared before the House of Commons Standing Committee on Health as part of its study on the Opioid Crisis in Canada.
Read the speaking notes
October 2016
Letter to Minister of Health on Health Accord Priorities
CPhA sent a letter to the Honourable Jane Philpott, Minister of Health, outlining its priorities for a new Health Accord, including improving drug access, investing in innovation and ensuring fairness for Canada's Indigenous peoples.
Read the letter
August 2016
Task Force on Marijuana Legalization and Regulation
CPhA submitted a brief in response to the issues outlined in the Task Force’s recent discussion paper (‘Toward the Legalization, Regulation and Restriction of Access to Marijuana’). The submission outlines CPhA’s priorities and recommendations for the legalization and regulation of marijuana, informed by research and consultation. CPhA is focused on improving the existing framework for medical cannabis through pharmacist management and dispensing. The submission also makes public health-focused recommendations to inform the legalization of recreational marijuana.
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August 2016
Federal Pre-Budget Consultation
CPhA submitted a brief to the federal pre-budget consultation highlighting three priorities for the 2017 federal budget to improve the health of Canadians. The recommendations focus on investing in optimal drug therapy for Canadians and enhancing drug access; educating Canadians about the health impacts of marijuana use, particularly as it relates to the medical use of marijuana and the risk of potential drug interactions; and improving health care for indigenous peoples through enhanced drug access and pharmacist services.
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May 2016
Letter to Minister of Health on Medical Marijuana Regulations
CPhA sent a letter to the Honourable Jane Philpott, Minister of Health, urging the government to consider including amendments to the Marihuana for Medical Purposes Regulations (MMPR) to allow pharmacists to dispense medical marijuana.
Read the letter
May 2016
Pharmacare — Standing Committee on Health
Perry Eisenschmid, CEO, and Phil Emberley, Director of Professional Affairs, appeared before the House of Commons Standing Committee on Health as part of its study on the development of a national pharmacare program.
Read the speaking notes
May 2016
Assisted Dying — Standing Senate Committee on Legal and Constitutional Affairs
Phil Emberley, Director of Professional Affairs, appeared before the Standing Senate Committee on Legal and Constitutional Affairs to testify on Bill C-14, An Act to amend the Criminal Code and to make related amendments to other Acts (medical assistance in dying).
Read the speaking notes
May 2016
Assisted Dying — Standing Committee on Justice and Human Rights
Phil Emberley, Director of Professional Affairs, appeared before the House of Commons Standing Committee on Justice and Human Rights to testify on Bill C-14, An Act to amend the Criminal Code and to make related amendments to other Acts (medical assistance in dying).
Read the speaking notes
February 2016
Federal Pre-Budget Consultation
CPhA submitted a brief to the federal pre-budget consultation highlighting three priorities for the 2016 federal budget to improve the health of Canadians, including improving drug access, the implementation of a national plan for e-prescribing and the development of a strengthened National Immunization Strategy.
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January 2016
Special Joint Committee on Physician-Assisted Dying (PDAM)
Carlo Berardi, Chair, Canadian Pharmacists Association, and Phil Emberley, Director of Professional Affairs, appeared before the Special Committee on Physician-Assisted Dying to represent the views of the pharmacist profession and discuss key pharmacy considerations, including drug access, protection of conscience, liability of health care professionals, oversight and appropriate support for pharmacists.
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Read the speaking notes
January 2016
Open Letter to Health Ministers
Ahead of the January 2016 F/P/T Health Ministers meeting in Vancouver, CPhA and its provincial pharmacy associations have released a joint, open letter to the Health Ministers which we hope will inform the discussion. The letter reiterates the important role of pharmacists as front line health care providers and highlights 3 issues of importance for pharmacists across the country, including drug access, assisted dying and prescription drug abuse.
Read the letter
November 2015
Assisted Dying — External Panel on Options for a Legislative Response to Carter v. Canada
Recognizing that the Supreme Court Decision in Carter v. Canada has important pharmacy practice implications, CPhA has been working with its members to ensure that Canadian pharmacists views and perspectives are represented in future legislation. A survey conducted by CPhA in October showed that the community sees a vital role for pharmacists but want rights of conscience protected. As such, CPhA participated in the Expert Panel consultations to highlight early considerations in the development of legislation as it pertains to pharmacy practice.
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View survey results
August 2015
CPhA response to the pre-consultation notice regarding Proposed Tamper-Resistant Properties of Drugs Regulations, as published June 27, 2015 in the Canada Gazette.
Read the letter
Read CPhA 2014 submission
March 2015
Bill S4, An Act to Amend the Personal Information Protection and Electronic Documents Act (PIPEDA) — House of Commons Standing Committee on Industry, Science and Technology
Janet Cooper, Vice President, Professional Affairs, appeared before the House of Commons Standing Committee on Industry, Science and Technology to discuss Bill S-4, An Act to amend the Personal Information Protection and Electronic Documents Act (PIPEDA).
Read the speaking notes
November 2014
E-cigarettes — House of Commons Standing Committee on Health
Glen Doucet, Vice President, Advocacy & Public Affairs, and Barry Power, consulting pharmacist, appeared before the House of Commons Standing Committee on Health as part of the committee’s hearings into the issue of e-cigarettes.
Read the speaking notes
Read the submitted brief (en français)
October 2014
Bill C-17, An Act to Amend the Food and Drugs Act (Vanessa's Law) — Senate Committee
Perry Eisenschmid, the Canadian Pharmacists Association's Chief Executive Officer, and Janet Cooper, Vice President, Professional and Membership Affairs, presented to the Senate Social Affairs, Science, and Technology Committee on proposed amendments to the Food and Drug Act known as Bill C-17.
Read the speaking notes in English
En francais
August 2014
Controlled Drugs and Substances Act re: tamper-resistant properties
CPhA presented a submission to Health Canada as part of its consultation on possible regulations to the Controlled Drugs and Substances Act regarding tamper resistant properties.
Read the submission
Read more about prescription drug abuse
June 2014
Prescription pharmaceuticals
Perry Eisenschmid, the Canadian Pharmacists Association's Chief Executive Officer, appeared before the Senate Social Affairs, Science, and Technology Committee for a roundtable on prescription pharmaceuticals in Canada.
June 2014
Bill C-17, An Act to Amend the Food and Drugs Act (Vanessa’s Law) — House of Commons Committee
Jeff Morrison, Director, Government Relations and Public Affairs, and Barry Power, consultant, discussed Bill C-17, An Act to Amend the Food and Drugs Act (Vanessa’s Law), with the House of Commons Standing Committee on Health.
April 2014
Study of the Best Practices and Federal Barriers Related to the Scope of Practice and Skills Training of Healthcare Professionals
Speaking notes to the House of Commons Standing Committee on Health
Official transcript of the proceedings, April 10, 2014
March 2014
Study on prescription pharmaceuticals in Canada — the nature of unintended consequences
Speaking notes to the Senate Committee on Social Affairs, Science and Technology
Official transcript of the proceedings, March 26, 2014
December 2013
Prescription drug abuse
Speaking notes to the House of Commons Standing Committee on Health
Official transcript of the proceedings, December 2, 2013
March 2013
Alberta Government Cuts to Generic Drug Prices
CPhA letter to Alberta Minister of Health re: Budget cuts to generic drug prices
March 2013
Marihuana for Medical Purposes Regulations (MMPR) consultations
CPhA's response to proposed Marihuana for Medical Purposes Regulations
February 2013
Off-label use of prescription drugs
Speaking notes to the Senate Committee on Social Affairs, Science, and Technology
Official transcript of the proceedings, February 27, 2013
May 2012
Cancellation of supplemental health benefits under the Interim Federal Health Program
Joint letter to Hon. Jason Kenney opposing cancellation of benefits
October 2011
Reviewing the 2004 Health Accord
Submission to the Senate Committee on Social Affairs, Science, and Technology
October 2011
Study on chronic disease and aging
Submission to the House of Commons Standing Committee on Health
August 2011
Pre-budget consultations
Submission to the House of Commons Finance Committee
July 2011
Medical Marihuana Consultations
Comments to Health Canada on the consultation document "Proposed
Improvements to Health Canada's Marihuana Medical Access Program"
December 2010
Application of GST/HST to professional non-dispensing pharmacy services
CPhA's request to Canada Revenue Agency for clarification of the issue
Canada Revenue Agency's Response to CPhA
October 2010
The role of pharmacists in the H1N1 pandemic and recommendations on how to improve future pandemic
Opening remarks and written brief to the Senate Committee on Social Affairs, Science and Technology
September 2010
Pan-Canadian bulk purchasing arrangement for common drugs