Policy and Political Action

Policy & Political Action

Response to CNO's draft Medication

Dear Amy,

The Registered Nurses’ Association of Ontario (RNAO) thanks the CNO for the opportunity to provide feedback on the draft revised practice standard, Medication.

We commend CNO for attempting to promote safe medication practice through a principled approach. The current draft is a step in the right direction, and we offer the following feedback for your consideration:

  • RNAO has received concern from nurses that the draft document, in the absence of supporting resources, lacks sufficient content to safely and effectively support practice. The solution may be to identify what resources are needed and include them as appendices to, or linked within, the revised draft.
  • Line 5 defines medication practices as “medication storage and inventory management, administration, dispensing, and disposal.” Furthermore, line 20 indicates that an order is required for a medication practice whenever the medication involved is a prescription medication. This requires an order for nurses to engage in medication storage and inventory management, as well as disposal. If this is intended, the implementation will be chaotic and result in a highly ineffective use of health resources.
  • Line 19 references controlled acts, however, a definition does not follow until the glossary. Given the importance of this term, it would be beneficial to include a definition earlier in the document.
  • Lines 53 and 54 indicate that medication reconciliation is a means of seeking information from a client about medication use. Medication reconciliation is further defined (beginning at line 135) as a systematic and comprehensive team review. However, it is not clear what the expectation is of the individual nurse. While medication reconciliation is a very important part of the nursing role, it would inappropriate for a nurse to engage in medication reconciliation each time he/she is engaged in a medication practice. Therefore, more clarity is needed around this requirement.
  • Line 60 requires nurses to “promote and implement strategies to minimize the risk of drug diversion.” This is very important, however, it is new to the standard and could benefit from greater clarity and resources to support nurses in understanding what this expectation means.

RNAO also recommends that CNO engage in a comprehensive education strategy when the revised standard is released, including broad outreach through webinars, teleconferences and other forms of communication ‐ to explain the changes, provide clarification where needed and answer questions.

Once again, RNAO appreciates the opportunity to provide feedback on the revised draft practice standard. Should CNO be interested, we will be pleased to work with CNO to support our recommendations.

Warm regards

Dr. Doris Grinspun, RN, MSN, PhD, LLD(hon), O.ONT. Chief Executive Officer
Registered Nurses' Association of Ontario

c. Lori Adler, Manager, Practice Standards, College of Nurses of Ontario Anne Coghlan, Executive Director and CEO, College of Nurses of Ontario

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