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Iowa Implements New Requirements for Non-Resident Pharmacies

Roger N. Morris
Health Law Alert

The Iowa Board of Pharmacy recently approved new rules regarding non-resident pharmacy practice that will become effective beginning January 1, 2018. Beginning in January, the pharmacist-in-charge (PIC) at every non-resident pharmacy will be required to register with the Board and renew annually. Non-resident pharmacies are pharmacies that are located outside of the state of Iowa that deliver, dispense, or distribute prescription drugs or devices to an ultimate user who is physically within the state of Iowa. Currently, there are approximately 1,000 non-resident pharmacies in the state of Iowa. This change will not require Iowa licensure for non-resident PICs, but the Board hopes that this registration will increase accessibility. In the past, the Board has had some difficulty contacting the PIC at some non-resident pharmacies due to frequent staffing changes. The change will also require completion of an educational training module regarding the Iowa rules as they relate to non-resident pharmacy practice. The module is entitled "Iowa Pharmacy Law Boot Camp: Education for Iowa Non-resident Pharmacies." (Available Here

The application itself will require basic information about the PIC, including name and contact information, the pharmacist’s license or registration number in the state the non-resident pharmacy is located, verification that the license is current and in good standing, the PIC’s current place of employment, and any criminal and disciplinary history information. It will also require a $75 nonrefundable administrative fee for processing. Similar to resident pharmacies in the state, a change in the PIC requires submission of a new application and fee. The pharmacy must submit notification of a temporary PIC within 10 days of the change, and a permanent PIC must be identified and registered with the Board no later than 90 days following the vacancy. Any changes in PIC information (name, contact information, home state license or registration status, and place of employment) must be reported to the Board in writing within 10 days of the change.

In addition to the PIC registration requirements, the Board will also require non-resident pharmacies that deliver controlled substances into Iowa to have an Iowa Controlled Substance Act (CSA) registration. This registration is completed using the same application described above and should be submitted along with a $90 non-refundable CSA registration application fee.

For more information, contact Roger N. Morris at (602) 229-5269/roger.morris@quarles.com, Brian F. King at (312) 715-5065/brian.king@quarles.com, or your Quarles &Brady attorney.

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