THE Ohio State of Licensure: New PIC Requirements

The Ohio Board of Pharmacy (Board) recently adopted significant revisions to its responsible person regulations for terminal distributors of dangerous drugs. Most notably, under paragraphs (C)(1)(a) and (H)(5) of the amended rule, Ohio Administrative Code 4729:5-2-01, effective February 1, 2027, the responsible person of non-resident pharmacies must be a pharmacist holding a valid Ohio pharmacist license. The Board published amended guidance, updated as of September 10, 2026, detailing the new responsible person licensure requirements.

The revised regulation also makes several operational changes affecting responsible persons, including:

• New supervision and work-hour requirements;
• Restrictions, and exceptions to those restrictions, on serving as the responsible person for multiple licensed locations;
• Quarterly on-site review obligations for certain license types; and
• Updated procedures for temporary and permanent responsible person changes.

The amended regulation continues to require all licensed terminal distributors to maintain a responsible person at all times and to notify the Board within ten days of a responsible person change.

With this change, Ohio will join Illinois and California, which have recently added requirements for non-resident pharmacies to have a pharmacist in charge (PIC) who is licensed in the state. Entities licensed by the Ohio Board of Pharmacy should review the new requirements carefully and consider whether operational, staffing, or licensure changes will be necessary before the effective date.

If you have questions about how Ohio’s new Responsible Person licensing or operational requirements may impact your operations, please contact your Quarles attorney or:

• Aaron Sagedahl: (612) 351-5054 / sagedahl@quarles.com
• Anne O’Brien: (312) 715-5259 / anne.o’brien@quarles.com