Explainer

Multi-state pharmacy licensing: who needs what

Why a pharmacy that ships across state lines needs a licence in your state too, what state boards ask of non-resident pharmacies, and how to check.

By the TrueRoute team · · 6 min read · General information, not legal or medical advice

Multi-state pharmacy licensing: who needs what

In short. A pharmacy that ships, mails or delivers prescriptions into a state usually needs that state’s non-resident pharmacy licence, as well as a licence in good standing at home. Each state board sets its own requirements. Check each licence on the boards’ own lookups, and confirm what applies to your clinic with your state board and counsel.

Why a pharmacy needs a licence in your state

Each state board of pharmacy regulates pharmacy practice in its state, and many treat a pharmacy elsewhere that ships, mails or delivers prescriptions to their residents as practising there. That is why a pharmacy located in one state and shipping into another commonly needs the second state’s non-resident pharmacy licence as well as its licence at home. Federal law adds its own layer for compounders: section 503A caps how much a 503A pharmacy may distribute across state lines, as FDA explains (see What is a 503A compounding pharmacy?).

For a clinic, this matters in both directions. The pharmacy that fills your patients’ prescriptions needs a licence in the states your patients are in. A pharmacy that will not tell you which states it is licensed in has answered a question anyway.

What a state asks of a non-resident pharmacy

The details differ state to state. Two examples, named as examples and not a national rule:

Missouri. The state’s rule for non-resident pharmacies says they “shall not ship, mail, or deliver prescription drugs into Missouri without first obtaining a pharmacy license from the Missouri Board of Pharmacy.” The pharmacy must also “maintain a pharmacy license in good standing from the state in which the nonresident pharmacy is located.” Missouri asks for an inspection within the last 18 months for a sterile compounding pharmacy, or within the last 24 months otherwise; where a state inspection is unavailable, it may accept one by the Missouri Board or through NABP’s Verified Pharmacy Program.

Oklahoma. A non-resident pharmacy is one not located in Oklahoma that transacts or does business in Oklahoma by soliciting, receiving, dispensing or delivering prescription medications and devices to Oklahoma residents. It needs an annual non-resident licence, a licence in good standing in its home state, an inspection report from within the previous 24 months, and an Oklahoma-licensed pharmacist in charge. Oklahoma’s pharmacy laws apply to the Oklahoma portion of the pharmacy’s practice.

Other states ask for different combinations, and some change their rules. The two above show the shape of the requirements: a licence at home in good standing, a separate licence where the patients are, a recent inspection, and the receiving state’s rules applying to that part of the practice.

A checklist for checking any pharmacy

  • Its home licence. Look the pharmacy up on the licence lookup of the board of pharmacy for the state it is located in. Read the licence: active status, expiry date, and whether compounding is on it.
  • Its licences in your patients’ states. Ask the pharmacy which states it ships to, then check the non-resident licence in each of those states on each board’s own lookup.
  • The board’s own record. Ask the board whether the pharmacy has any board actions. Registration with a federal program is not a state licence and does not replace one.
  • Who to ask. NABP keeps a list of every state board of pharmacy, with each board’s own lookup and contacts. Confirm what applies to your clinic with your state board of pharmacy and your own counsel.

Where TrueRoute fits

TrueRoute is ordering software, not a pharmacy, and never prescribes. Orders are filled by licensed pharmacies in our network, and each pharmacy holds its own state licensure and makes its own dispensing decisions.

A patient prescription and an office-use purchase are separate orders in TrueRoute; office-use purchasing is available once your account’s program is set up. Prescribers on the account are NPI-validated and clinic-attested. Every order keeps its status, payment and fulfillment on one append-only record, so what was ordered, when and by whom is written down once and not rewritten.

The pharmacy network · How an order works

Questions

  • Why would a pharmacy need a licence in my patients’ state?

    Because many state boards require a pharmacy that ships, mails or delivers prescriptions into their state to hold their licence, even when the pharmacy sits somewhere else. Missouri and Oklahoma, for example, both require a non-resident pharmacy licence on top of a licence in good standing in the pharmacy’s home state.

    The details are set by each state’s board of pharmacy, so confirm the rules for your patients’ states with each board and your own counsel.

  • What do states typically ask of a non-resident pharmacy?

    Two examples, named as examples and not a national rule. Missouri asks that a non-resident pharmacy first obtain a Missouri pharmacy licence, and that it maintain a pharmacy licence in good standing from the state in which it is located. Oklahoma asks for an annual non-resident licence, a licence in good standing in the pharmacy’s home state, an inspection report, and an Oklahoma-licensed pharmacist in charge.

    Both states apply their own pharmacy rules to the part of the pharmacy’s practice that touches their residents. Every state sets its own requirements: check each board, and confirm with counsel.

  • How do I check a pharmacy’s licences myself?

    Look the pharmacy up in the licence lookup on the website of each state board of pharmacy involved: the state the pharmacy is located in, and each state it ships to for your patients. NABP keeps a list of every state board.

    Ask the supplier which states it is licensed in, then read those licences on the boards’ own lookups rather than taking a certificate image as proof.

  • Does TrueRoute check the pharmacies in its network?

    TrueRoute is ordering software, not a pharmacy, and never prescribes. Orders are filled by licensed pharmacies in our network, and each holds its own state licensure. Confirming which licences a clinic relies on, and how it confirms them, stays the clinic’s decision: check with your state board of pharmacy and your own counsel.

Prescriptions and purchases, kept apart.

Tell us what you order today, and we will show you both paths with your products.