Pharmacy marketing in BC: the loyalty point ban, the advertising bylaw and the homepage checklist

Section 15 of the Community Pharmacy Standards of Practice in the College's bylaws prohibits a registrant from providing, distributing or being party to an incentive given to a patient for the purpose of inducing them to deliver a prescription to a particular pharmacy or obtain any other pharmacy service from it. The bylaws define incentive broadly: money, gifts, discounts, rebates, refunds, customer loyalty schemes, coupons, goods or rewards.

Three things are carved out: free or discounted parking, free or discounted delivery, and accepting payment by a credit or debit card linked to an incentive programme. The prohibition also leaves out unscheduled drugs and Schedule III drugs unless a practitioner prescribed them.

The rule has history. The College first adopted the bylaws in December 2013, a court struck them in 2014, and the BC Court of Appeal restored them in January 2016. The College's registrar described redeemable points on prescriptions as unethical, unsafe and unprofessional.

Part IX of the bylaws governs marketing. Any marketing of a registrant's professional services must contain nothing false, inaccurate, unverifiable or reasonably expected to mislead the public. Marketing breaches that standard if it is likely to take advantage of a recipient's weakened physical, mental or emotional state, creates an unjustified expectation about results, implies results beyond what other registrants can achieve, or compares the quality of services with those of another registrant, another health profession or a provider under another enactment.

Prescription drug price advertising has its own format. The ad must give the brand name, the generic name and manufacturer, the dosage form and strength, the total price for a stated quantity, and the phrase only available by prescription, and it may refer neither to the drug's safety, effectiveness or indications nor to another pharmacy's fees. Advertising for services the province requires of every pharmacy must say Required in all British Columbia Pharmacies with equal prominence.

The bylaws reach into web design. A pharmacy's website homepage must clearly show that the pharmacy is licensed in British Columbia, the contact information for the College, a notice that pharmacy practice issues may be reported to the College, the pharmacy's physical location, its ten digit telephone number and the name of the pharmacy manager.

That is a fixed block of content on the most valuable screen a pharmacy owns. Designed once as part of the brand system, it reads as reassurance; squeezed in later, it reads as clutter.

With loyalty points barred and comparisons out, an independent pharmacy's advantages are service and identity: the pharmacist patients know by name, compounding, medication reviews, delivery, and a neighbourhood the chain has no way to describe. The bylaws leave every one of those open.

A clear statement of who the pharmacy serves, named pharmacists, and a homepage that meets the bylaw while still looking like a brand do more for an independent than any programme the bylaw bans.