The Pennsylvania Board of Pharmacy has indicated its intent to begin enforcement of Pennsylvania's new non-resident pharmacy licensure requirement on December 7, 2015. Non-resident pharmacies with Pennsylvania operations should apply for a non-resident pharmacy license as soon as possible. The application is available through the Board's website and requirements include, among other things:
the submission of a $125 fee;
a copy of the pharmacy's resident state license;
the provision of a letter of good standing or license verification from the resident state Board of Pharmacy directly to the Pennsylvania Board; and
a copy of a sample prescription label including the pharmacy's toll-free phone number.
On October 7, 2015, Pennsylvania enacted legislation requiring non-resident pharmacies to register with the Pennsylvania Board of Pharmacy before delivering prescriptions to Pennsylvania patients or advertising in Pennsylvania.
To ensure compliance and prevent any disruption to operations, out-of-state pharmacies currently shipping product to Pennsylvania patients should apply for Pennsylvania licensure as soon as possible. Regulators have advised pharmacies to allow at least two weeks for the processing of applications, meaning pharmacies should attempt to submit their applications by November 23, 2015.
Pennsylvania does not require that the non-resident pharmacy's designated pharmacist-in-charge hold a Pennsylvania pharmacist license.
As noted in our previous alert, the licensure requirement will create new compliance obligations for non-resident pharmacies with operations in Pennsylvania.
If you have questions about Pennsylvania's new non-resident licensure requirement, please contact the authors of this alert or any member of our Specialty Pharmacy team.