Unfair treatment by the Alberta College of Pharmacist registrar Greg Eberhart and Monty Stanowich, Compliance Officer
Written and updated by Dr. Kamal Alhallak, Ph.D. in Pharmacy and Pharmaceutical sciences
During the last year, I have been dealing extensively with the Alberta College of Pharmacy, in general, and the registrar in specific. To avoid rewriting a reply with every new complaint, or explaining the details times and times again. I decided to put everything under one webpage.
Mr. Eberhart has been the ACP registrar for the last 30 years! As his Linkedin profile shows, he was appointed as a registrar of the Alberta Pharmaceutical Association (APhA) in 1990. At that time Mr. Eberhart has only five years of management experience at London drugs. In 1995, he was reappointed for one more term between 1995 to 2000.
After dissolving the APhA in 2000 to form Alberta College of Pharmacists ACP and Alberta Pharmacist’s Association RXA. Therefore, Alberta College of Pharmacists emerged as the regulatory body for all Pharmacists in Alberta. Therefore, the ACP was in need of new bylaws, standards of practice, and a registrar. Mr. Eberhart was as a registrar re-appointed as a registrar for a new term in 2000 and has been serving in the same position until now. In 2017 the ACP changed their name to Alberta college of Pharmacy.
The ACP code of ethics states that Pharmacists and pharmacy technicians use their knowledge, skills and resources to
In the transition between the APhA and the ACP, several bylaws were amended or implemented the year 2000, or after, bylaw #37 is one of them implemented in the year 2000. This bylaw allows the registrar to keep the position forever as it reads ” Council may reappointed the registrar to more than one term in office” On the contrary, the elected president of the ACP would serve only one term of two years! There is bylaw regarding any committee responsible for evaluation of the registrar performance or succession similar to other Registrar Evaluation & Succession Planning Committee
Here is a link for the full ACP bylaws click here
To my knowledge, Mr. Eberhart did not pursue any training or education in public relations, the management sciences, or any other fields that might make him irreplaceable as a registrar. However, the bylaw 37 along with lack of evaluation and accountability, or a mechanism for succession, made it impossible to replace him. It seems to me that the first ACP council failed to realize consequences of this bylaws.
According to Wikipedia, “A dictatorship is an authoritarian form of government, characterized by a single leader or group of leaders and little or no toleration” Even Sir. Winston Churchill served only two terms as PM! However, the ACP registrar is serving his 6th term! I looked at the list of current longest ruling non-royal national leaders. There is currently only six non-royal leaders who served over 30 years!
Simply, No. A study has shown that an average CEO tenure is 7.4 years. Moreover, a review study published in Business Harvard Reviews (BHR) showed that longer tenure results in declining performance. This is logical as every organization or regulatory body requires continuous modernization. New leadership brings in ideas and innovation, which we lack at the ACP. Our registrar belongs to a different generation, and it seems that he had little room and toleration for new forms of pharmacy practice. Moreover, when a person takes over a leadership position for as long as 30 years, it becomes natural for him/her to feel that he is above the law, or even the act itself. Now to the ethical part, I do believe that Mr. Eberhart should have favored the pharmacist profession over his personal interest of keeping his position. How is that ethical or logical to have the same person get re-appointed by six different elected councils. Moreover,The ACP under Mr. Eberhart leadership failed to develop new leaders and prepare them for inevitable succession process.
Health professions, including pharmacy, are ever-evolving ones. Moreover, self-regulated health professionals continuously face and overcome new challenges every day by acquiring new skills and competencies. This is achieved through training and education and with the support of the colleges by adapting and modifying new standards and bylaws. This task requires dynamic mentality and critical thinking skills to maintain a balance between the protection of the public and the continuous evolution of diverse health professions.
For example, the tremendous effort of the ACP allowed Pharmacists to have a more significant role in the community. We, as ACP regulated members witnessed the shift towards patient-focused health care, which grew the last decade more than it did since establishing the ACP.
Since the approval of Cosmetic Botox by the FDA in April 2002 for the treatment of moderate to severe glabellar lines, cosmetic and aesthetic non-surgical non-invasive practice proved to be a promising field with high patient and community demands. Some colleges such as CARNA and CPSA realized the potential of this field and took steps to incorporate it within their regulated member’s standard of practice. Moreover, they realized that under and post-graduate programs in nursing and medical school do not offer any training or education tailored exceplicitly for the cosmetic fields. Therefore, the CPSA and CARNA decided that it is up to the regulated member to acquire the skill and competencies through training and self-education prior to practicing cosmetic injections.
In regards to cosmetic injections, the ACP, under Mr. Eberhart leadership, failed to caught up with other peer regulatory colleges. Moreover, they did not publish any standards or bylaws in this regard. In the contrary other self-regulated health professional acknowledged Pharmacists in this field more than our college (CARNA Acknowleged that a nurse would be able to inject Botox injection after receiving an order from a Pharmacist with addition prescribing authority)
Dec 12th, 2016
I communicated with the ACP to inform them that I will start my practice in cosmetic injections. Jennifer Voice replied that it is my responsibility to acquire training and competence. in 2018, Jennifer has asked one Pharmacist, who is my employees, about my cosmetic practice, during a regular practice assessment. This indicates that the ACP practice consultant is fully aware of my practice in the cosmetic field
Please click on the photo below to see the full media file.
April 4th, 2017
We launched Albany Cosmetic and Laser Center Albanylaser.ca as a premium provider for laser and cosmetic injections. All Accounts with Pharmaceutical providers (Allergan and Galderma) were opened under my name. I provided them will my information such as my ACP licenses and list of my training certificate.
June 5th 2018
A letter from the College of Physcians and Surgeon Alberta (CPSA) informing me that they are investigating me for using the protected abbreviation “Dr.”
Aug 7th, 2018
the associate complaint director at the CPSA sent me an email stating that “The investigation initiated against you has been formally resolved with all matters settled to the satisfaction of the College of Physician & Surgeons of Alberta.”
I also received a letter stating that I am eligible to the title “Dr.” does not conterven with Health Professional ACT since I have Ph.D. in Pharmaceutical Sciences
Nov 4th, 2018,
I received a call from Mr. Jim Krempien from the ACP complaint department. He discussed an anonymous tip submitted by email from ([email protected]
Mr. Krempien stated that the ACP does not have an official record for my Ph.D., even though I informed the college of my Ph.D. since 2012. Moreover, I kept indicating that with every license renewal. To this point, all official communication with the email (digital and hardcopy) address me as Mr. Alhallak.
Mr. Krempien suggested minor changes to the website, which we did instantly. Mr. Krempien was satisfied with the modifications we added to the website to make it clearer that I am a Ph.D. not an M.D.
On Nov 8th, 2018 we recieved nasty reply from [email protected]
I found later on that the necolette Richardson is an alias name for one off our competitor in the cosmetic field
March 11th, 2019
1- The first letter Indicated that Mr. Stanowich was appointed to inspect my practice at Albany Cosmetic and Laser Center.
2- The second and third letter indicated that Mr. Stanowich would conduct an inspection of the practice and operation at Westwood Pharmacy and Health Aid Pharmacy.
Both letters addressed me as Mr. Alhallak. I communicated with Mr. Stanoiwch, and he confirmed, at that time, that the college does not have my Ph.D. on file. I expressed concerns about the level of ACP hostility, by inspecting three locations under my management simultaneously!
Mr. Stanowich sent the following email “Essentially; my understanding is that based on the services offered on the website, ACP has questions about the nature of the pharmacy practice occurring at this location. Additionally, there are questions about the nature of the relationship with the two pharmacies. Health Aid Pharmacy is co-located with Albany, and you are the licensee of Westwood as well as being a proprietor of both. Further to these questions, Mr. Eberhart has requested that I conduct an inspection under the Health Professions Act (HPA) to provide him with more information on your practice. As indicated in the initial letters, he sent to you, after I inspect the practice, I will provide him a report of my findings for his consideration. An important distinction to note is that this is an inspection under Part 3.1 of the HPA with the intention of providing information to the Registrar, and not an investigation under Part 4 of the HPA that would occur pursuant to a formal complaint. If you have additional questions, I would be happy to discuss them on Friday as I am able.”
I complied with the request and we set a meeting for March 15th
March 15th, 2019
Mr. Stanowich showed up at the meeting within three days of receiving the ACP letter. It was apparent that he did long preparation for this inspection, way more than three days. He informed me that Mr. Eberhart received an inquiry from the minister of health about my practice in the cosmetic field. Mr. Eberhart nor the ACP, due to the lack of communication, had a record of my higher education or training. Yet, they decided to launch a witch hunt as you will see.
He started asking all types of questions with no orientation or limitation. We discussed some relevant points in detail, such as patient assessment, charting, injection process, insurance, my training, communication with other health professionals.
I raised my objection on other points such as billing, ownership, corporate structure, laser training. I explained to him that the college has the right to inspect aspects related to my practice. However, other elements pertaining to non-restricted activities are outside the ACP scope. Moreover, I informed him that I am not willing to discuss anything related to my “Dr.” title, as this matter has been dealt with.
Mr. Stanowich trespassed to every room in the center; he took pictures of our laser machine (which are registered with CPSA), he interviewed the staff that works there, took photos of the training certificates. When I objected, he threatened me with professional misconduct! He asked many questions about non-restricted activities such as laser treatments, micro-needling.
He focused on the vaginal treatment at Albany Cosmetic and Laser Center. I informed him that we have a board-certified GYN, Dr. Abdulhafez, responsible for this part of the procedure. He kept asking a question about the details of this treatment, and I showed him that the machines were still in wrapping, and we had not had training for it yet. My involvement was merely in providing logistics and marketing support. However, he kept pressing on this matter. He sounded very disappointed that he would not be able to catch me on this issue.
I want to highlight some critical points
1- Mr. Stanowich asked me how do I evaluate my skills as Botox injector. My answer was (honestly, I believe that I am the best cosmetic injector in Alberta, I am the one who does the patient assessment, inject, and follow up. All other famous dermatologists and physicians have Nurses and LPN doing the injection and follow up. They do not even see the patients)
2- I did the vaginal injection training in the USA. However, I have not provided the treatment yet.
3-By the end of the meeting, Mr. Stanowich told me he is “Very Satisfied” and “has no concerned.” He added that he might not need to visit Westwood Pharmacy, but he will confirm that later on. He told me if that happened, it would be only out of formality
4- I explained to him that what we provide at Albany is cosmetic treatment and it would not interfere with any medical care plans developed by other health professionals. Therefore, I do not see a reason for me to inform other health professionals with the procedures and injections. Moreover, lots of clients ask for secrecy regarding this matter. To add to this issue, only pharmacists are obligated to to communicate with other health professional regarding prescribing activities. Usually all activities are posted on Netcare and non of the other prescriber such as NP, physicians or dentists communicate with us thier prescribing activities! This is how the Alberta College of Pharmacy registrar perceived Pharmacist as health professionals.
5- As he was “satisfied” with the inspection results at Albany, his possible visit to Westwood would unnecessary or very brief. He ensured me that this is not a practice assessment and he promised that he would not discuss aspects
Later that day, I received an email from Mr. Stanowich that he decided to make a brief visit to make sure I do not push my patient to come to Albany.
March 19th, 2019
Mr. Stanowich showed up at Westwood Pharmacy, and his inspection was a disaster. He showed unprecedented level of unprofessional attitude and lack of training and education. He re-asked all the questions that he asked at Albany Cosmetic and Laser center, questioned by judgement about renewal a diabetes medication, interrogated and harrased my staff.
I explained to him that I am one of the highest educated pharmacist in Canada. I have Ph.D., M.Sc. CDE, CRA, CPG and I am doing my MBA. I graduated 8 interns who are all workign for me as pharmacists. Mr. Stanowich’s lack of training made him feel personally insulted! He asked me if I believe that I am smarter than him, I asnwered him that I know I have higher education is some fields such as diebetes. He ridiculed my Ph.D. and my education in front of my staff.
I asked him specifically what happened to his promise, and asked him infront of my staff if he was satisfied by his visit to Albany, and he answered yes! He add that he has the right to ask any questions. He could expand the inspection to invlove other pharmacy connected to me. He said, he can pullout at any pharmacy and inspect it with no prior notice or reason. I explained to him that this intimidation tactic is useless and unprofessional
Mr. Stanowich was so agitated he decided to leave, and not to continue the inspection. eventually he left and forgot his bag in the pharmacy.
It want to highlight these points:
1- I asked Mr. Stanowich specifically if he was satisfied with Albany Cosmetic and Laser center. His answer was “Yes”
2- I reminded Mr. Stanoiwch about the objective of his inspection at Westwood Pharmacy. He said that he keeps forgetting as he is used to the regular pharmacy practice assessment
3- He asked me infront of my staff about the weight of my Ph.D. in a sarcatic manner
4- In his report, he mention that ” I was not able to provide evidences about my designation as CRE, CDE, GPC. He spent almost three hours in the pharmacy and took pictures of every corner, but he failed to notice the certification hanged on the wall.
Th interaction happened in the presence of three of Westwood Pharmacy Staff. Pharmacist Refqa Bader, Tahmina Karini and Radya Bader. I am willing to share there contact informations as I have consent from them to do so.
Mr. Stanwoich has been away from actual pharmacy practice and patient communications for years! I am not sure what kind of training he gets to keep updated with new therapeutic guidelines and agents. It is not my job to educate him about the diabetes and why I chose to prescribe or renew a therapeutic agent for one of my patients.
I tried to reach out to the registrar and sent him several request for a meeting, but Mr. Eberhart refused to meet me and asked me to wait for the report. I reached out to the former president of the ACP, Stan Dyjur, complaining about the unfair treatment from the ACP registrar and staff members, but stated “It is inappropriate for myself or any other council member to meet while this inspection is underway.”
Mr. Dyjur, at that time, was the elected president of the ACP. Supposedly, he over see the registrar, I reached him for a meeting, as I wanted to echo my concerns. He dismissed simply becuase it is not appropriate! At this point, it is just inspection to collect information and there was not comlaint against me at the complaint department.
I informed him that this is suppose to be inspection to collect information, there is not complaint or public concern, but he kept refusing to meet me and block me from meeting any council member. I sounded like Stand was helpless and he was specifically asked to setp aside, I am not surprised that Mr. Eberhart managed to get himself re-appointed for 30 years. This is a toxic and supressive environment, when an elected president refuses to meet with an ACP member becuase simply it is not appropriate! I believe that my rights is more important than being “inappropriate” the Mr. Eberhart.
Moreover, I communicated with Craig Macalpine and tried to meet him, but he told me literally that he was told he is no allowed to see me! At this time point, the inspection was meant to collect information. In other words, the college were supposed to hear from me as well. Yet the registrar decided to block all my attempts of communication.
April 9th, 2019
Consultation on amendments to the Standards of Practice regarding. a new standard that provides limits on the insertion or removal of instruments, devices, or fingers under section 16(1)(d)(i) and (ii) of the Pharmacists and Pharmacy beyond labia majora. Since I do not believe in coincidence, I raised a concern about being personally targeted by the this amendment, and raised my concerns about the timing (Power abuse)
April 17th, 2019
I recieved an additional email from Mr. Stanowich asking additional questions. Basically, we are one month after the inspection started and he still collection information about me. The questions are mainly related to me personally and has nothing to do with my practice.
May 29th, 2019
I received Mr. Stanowich report and a letter from Mr. Eberhart inviting me to submit my reply by September 6th. The letter heading addressed me as Mr. Alhallak; therefore, I objected to the insistence of the ACP staff and registrar to ignore my title and asked for the letter to be changed. n May 3rd, Mr. Eberhart sent me a letter addressing me as Dr. Alhallak, but also correcting the date from September 6th to June 6th. This means that his inital intention is to give me only one week to reply (power abuse)
In other words, Mr. Stanowich had three months of preparation between Jan and March 2019 and three months to write a report. Yet Mr. Eberhart gave me one week to reply to the 40 pages report.
In Mr. Stanowich’s report, my practice as community pharmacist and cosmetic injector is not up to the standards. Nothing is positive about it and I would benefit from education and maybe discipline.
Interestingly enough, Westwood Pharmacy went through practice assessment lead by Mr. Tyler Watson at the exact same peroid. He did not raised any concerns about our pharmacy practice we have at Westwood Pharmacy. In the contrary, our interaction with him was professional and progressive. Attached is his email. This is a clear evidence of Mr. Stanowich biased report. How could two different ACP staff report the same practice in contradicting way? (biased Report)
It is also important to mention the appreciation that our community at Westwood Pharmacy is showing. This is evident by the perfect feedback and sincere message we recieved every day
Mr. Stanowich report was personal, biased ans subjective. It ignored the main objects for the inspection and decided to follow me personally. Please read the conclucion remarks, the full report with my reply to it.
Moreover I sent an official complaint against Mr. Stanowich, and two requests to the college. The first to provide me with more transperancy reagrding the communication during this inspection, and the second to put more effort to acknowledge pharmacists in the cosmetic field
I also provided an official letter confirming that Dr. Abdulhafez is the health professional responsible for all women health department including the vaginal treatment.
As Expected after about three months of submitting my reply. Mr. Eberhart decided that my case has to be referred to the complaint department. He refuse to direct my complaint to the complaint department and decided that Mr. Stanowich acted within his rights as inspector. I believe that is a huge conflict of interest, the registrar and the field officer are the same team, and my complaint should have been taking more seriously, not dismissed with a simple letter from the registrar.
Our registrar failed to differentiate between Pharmacist and Pharmacy practice when he cited the Pharmacy and Drug act-section 3. The ACP has lately changed its formal name from the College of Pharmacists to the College of Pharmacies to acknowledge the difference. The difference between Pharmacy and pharmacist is similar to the difference between clinic and physician.
Mr. Eberhart urged the complaint department to investigate me for lack of knowledge! After over 16 years of research, education, community and cosmetic practice, he decided that I lack the knowledge! Within four years of practicing cosmetic pharmacist injector, our center was able to gain the highest client satisfaction rate in Alberta with 181 votes and 4.8/5 stars. To this moment, there are no complaints or adverse reactions were reported due to treatment provided at our Laser Center.
During this inspection, the ACP team tried their best to ridicule my higher education instead of embracing it. The kept repeating that I am fooling the people and impersonating an M.D. It is clearly stated that my righteous Dr. title comes for my Ph.D.. it is clearly stated that I am a Pharmacist, not a physician! Moreover, I believe that my educations, credentials, and skills are higher than the average physician
I received a letter from the ACP complaint department about a complaint from a Physician who works in Red Deer. I was shocked that some from Red Deer would be bothered by my practice. The claim was degrading, outdated, and full of misinformation. The complaint has been practicing in their private clinic and is designated as medical director for a medical spa inside her clinic, they have been practicing in Red Deer since the seventies. The report showed that the complainer is outdated in her information and not keeping up with the new innovation in the cosmetic field. Moreover, she not aware that Pharmacist has the authority to prescribe and inject, and still have the same old stereotypical image about the Pharmacists being a pill counter. Moreover, the complainer could not wait for the ACP reply, but mentioned that they reported me to the college of physician, ministry of health, all the pharmaceutical companies, and training centers. Mr. Krempien informed me that he appointed Jennifer Mosher as a special investigator, and asked me to take my time regarding the reply.
It is important to mention that Mr. Greg Eberhart the ACP registrar is originally from Red Deer, and he practiced as a Pharmacist in Red Deer from 1977 to 1990 (I realized the coincidence on Dec 20th, 2019
Sep 6th, 2019
Within two weeks of complaint submitted by the Physcian in Red Deer, I received a letter from the ACP registrar, Mr. Eberhart, informing me that he decided to escalate the inspection into the investigation. Moreover, he stated that he gave me the time to reply as a courtesy.
This courtesy from the ACP registrar contradicts with his first letter, dated March 11th. The letter stated according to section 54.3 of the Professional Health Act I would receive a copy of the report! I do believe that the purpose of this copy is for me to send my reply and comments. This is exactly the mentality the Greg Eberhart, he is the law! Even the week he granted me to reply to 40-page report is a courtesy, not my lawful right. One week of courtesy to reply for a report that took Mr. Monty Stanowich over six months to prepare!
Oct 10th, 2019
As requested by Mr. Eberhart, the ACP complaint department started a new investigation. The investigation was led by Mr. Jennifer Mosher. We went through the some questions again. She told me that Mr. Eberhart asked her specifically to investigate the inducement I offer, in form of discounts, to my clients. This question reflect the outdate mentality of our registar and lack of ability to realize the difference between a pharmacy and a cosmetic center. Moreover, it gives an indication about his determination on building a case against me. It is illegal to offer discount and inducement in a pharmacy, However, Albany Cosmetic and laser Center is not a pharmacy. Offering discounts on cosmetic treatments is a common practice in all dermatology clinic and medical spa.
After meeting with Ms. Mosher, she sent another emial to Dr. Abdulhafez and myself asking about the vaginal treatment.
I answered as following
“Thanks for your email, Jennifer. To answer your question, No, I did not perform nor attend any vaginal treatment or training for any patients in Canada. I am not involved in any consultation nor meeting any patient or client in regard to women’s health, I do not collect information or provide advice of any sort in this regard. I can provide a sworn affidavit if you wish. I provided a letter from Dr. Abdulhafed, whom you interviewed, stating that he is responsible for any and all vaginal treatments at Albany cosmetic and laser Center. Since I declared that I am not involved in any practice that is related to the women’s health and vaginal treatment in Albany Cosmetic and Laser center or any pharmaceutical or medical facilities in Canad, this makes the whole issue outside the scope of ACP.
Dec 2nd, 2019
After many attempts to communicate with the ACP previous and current president. I recieved an encouraging letter from Mr. Fayaz Ali, the current ACP president.