Virtual Facilities (Resolution 122-2-26)
RESOLUTION NO: 122-2-26
TITLE: Virtual Facilities
ACTION: PASS
WHEREAS, virtual manufacturers and virtual wholesale distributors are becoming more prevalent; and
WHEREAS, only 11 states have a virtual-specific manufacturer and wholesale distributor license category, 17 states have virtual-specific applications for a manufacturer or wholesale distributor license, eight states have manufacturer or wholesaler applications that include both physical and virtual types of entities, and 14 states consider virtual entities exempt; and
WHEREAS, the Model State Pharmacy Act and Model Rules of the National Association of Boards of Pharmacy (Model Act) does not distinguish between the standards for a virtual facility compared to a traditional facility that physically possesses drugs; and
WHEREAS, a designated representative is not required to be licensed but does assume responsibility for ensuring compliance and mitigating risks with diversion and counterfeit activities;
THEREFORE, BE IT RESOLVED that NABP convene a work group to recommend amendments to the Model Act that include virtual-specific license requirements for manufacturers and wholesale distributors, specific requirements that are appropriate for a facility that does not physically possess drugs, and language related to whether designated representatives should be licensed.
(Resolution passed at the 122nd Annual Meeting in Boston, MA.)