Many stakeholders have noted that only a small number of physicians dispense drugs as a part of their practice. The now eased physician-only dispensing requirement from Health Canada made the dispensing of Mifegymiso more heavily regulated than medications in the Controlled Substances Act. There were concerns about how access to the medications could by impaired by this restriction. In response, the colleges of physicians and pharmacists in Ontario and British Columbia have expressed concerns to Health Canada that these requirements were outside of the normal distribution system for medications and would make dispensing Mifegymiso challenging. This requirement has the potential to prevent the incentivization of physicians, particularly if they are in rural areas and do not have access to the necessary resources and infrastructures to stock medication on site.
Since coming under critique, Health Canada confirmed on May 18th 2017 that Territorial and provincial professional bodies representing physicians and pharmacists determine distribution systems.
Indeed, having pharmacists dispense Mifegymiso directly to patients falls within the scope of a physician's ability to prescribe off-label. In the words of the Ontario College of Pharmacists, "the product monograph is not a legally binding document. If, under the practice of medicine or pharmacy, the administration or distribution of the medication is outside of what is approved in the product monograph, the product would be used off-label." Since then, five provincial governing bodies of pharmacist professionals produced guidelines in support of pharmacists and pharmacy technicians involvement in dispensing Mifegymiso directly to patients. Those five provinces are British Columbia, Ontario, Alberta, Nova Scotia and Saskatchewan.
Action Canada for Sexual Health and Rights welcomes the announcement made on May 18th addressing the barriers imposed on the distribution of Mifegymiso. That said, many provincial and territorial professional bodies have not yet issued clarifications in support of pharmacist dispensing, making it essential that Health Canada clarify their stance on physician-only dispensing as it is still a barrier in many regions.