Verified Pharmacy Program

The following eligibility requirements must be met for NABP to conduct a VPP inspection of the applicant facility. A facility that is unable to meet these eligibility requirements will have their application closed in accordance with the program terms and conditions.

1. Facility must be a licensed pharmacy operating in the United States or Puerto Rico with an active license in its resident state.
2. Pharmacy location must not be a personal residence.
3. Pharmacy location must be operational (see definition below) in all its activities for at least 30 days.
4. The pharmacy is currently not under investigation, subject to one or more health care-related disciplinary or pending administrative or civil complaints, criminal proceedings, or regulatory or law enforcement investigations including, without limitation, product or document seizures by a regulatory agency or governmental authority.
   • In general, civil complaints from patients, businesses, or other non-governmental agencies are not considered pending discipline (ie, a breach of contract, medication error).
   • Unless the pending discipline is from the pharmacy’s resident state, minor violations that are a result of a finalized settlement or related disciplinary action that alleges no further violations (eg, piggybacked disciplinary action) may not make the pharmacy ineligible.
   • Any disciplinary actions from a governmental authority are still considered pending, and not considered finalized, unless signed by the applicant and the governmental agency, and filed under local, state, federal, or jurisdictional requirements.
5. The pharmacy completes and submits an online application, which includes agreeing to the program terms and conditions, and remitting the applicable payment.

The following operational requirements must be met for NABP to conduct and complete a VPP inspection. NABP publishes these requirements to support the preparedness of the applicant. NABP obtains applicant’s agreement to adhere to each of these operational requirements. At any time upon which the applicant has not met all operational requirements, whether upon arrival of the inspector at the facility or during the inspection, NABP will cease the inspection, retain the full inspection payment, not issue a refund to the facility, and have the facility sign an incomplete inspection form that will be made available for the Boards of Pharmacy to request from NABP. 

1. The pharmacy must have sufficient records for review to demonstrate it was actively engaged in the practice of pharmacy prior to application.
   • Sufficient number of records shall not be less than 10 individual patient profiles for review involving prescription drugs and/or prescription devices.
   • Practice of Pharmacy is defined as, “the interpretation, evaluation, dispensing, and/or implementation of medical orders, and the initiation and provision of Pharmacist Care Services.” 
   • Types of activities that are considered part of the practice of pharmacy include, but are not limited to: interpreting prescriptions; dispensing prescription drugs and devices; compounding drug preparations; counseling patients; performing drug use review; performing medication therapy management reviews; consultation with prescribers and other members of the health care team; administration of vaccines, immunizations, and other drugs as permitted under a collaborative practice agreement or protocol; and delivering patient care under collaborative practice agreements or pharmacist care services. 
   • Records of the practice of pharmacy must be readily retrievable and available for review during the inspection, whether available on paper or electronically.
2. The pharmacy must be open a minimum of 1 day out of the week and a sufficient number of hours for inspection purposes.
   • Sufficient number of hours means:
     • Meets all state requirements for hours of operation; 
     • Has a licensed pharmacist onsite during hours of operation; 
     • If billing for Medicare B equipment and supplies, meets the CMS Supplier standards minimum requirements for hours of operation; 
     • If performing sterile compounding, is open a minimum of 8 hours per operational day; and 
     • If not performing sterile compounding, is open a minimum of 4 hours per operational day and the licensed pharmacist agrees to stay on premises if the inspection lasts longer than the hours of operation.
   • There are no signs, posted communication, telephone messaging, or information on the pharmacy’s website citing they are closed.
3. For applicants who are compounding drug preparations:
   • Compounding must have occurred prior to application for a minimum of 30 days.
   • The pharmacy must be able to demonstrate compounding activities utilizing facility, equipment, drugs, and supplies. 
   • A sufficient number of compounding records shall be available for review. 
   • Training must be documented for all staff actively involved in compounding. 
   • If sterile compounding,
     • Certification reports for all primary engineering controls and secondary engineering controls shall be available for review; and 
     • All construction/remodeling on sterile compounding suite must be completed.
4. If sterile compounding, the pharmacy must have certification reports dated within 6 months of application payment date.  
5. The pharmacy is not actively engaged in construction/remodeling that impedes the activity of the pharmacy.