VPP Frequently Asked Questions
- Am I able to cancel my VPP application?
- How long will it take for my application to be processed?
- Does my pharmacy have to be licensed in the state of domicile for a year before I can obtain licensure in another state?
- Who notifies the Board that I have applied for nonresident licensure?
- What are the next steps after I’ve submitted a VPP application?
- What if I have a change to my application?
- What if I need to place a hold on my unannounced inspection?
- What can I expect for the VPP uniform inspection?
- What are the next steps after I’ve had a VPP inspection?
- In what format should my responses to my completed inspection be submitted?
- Will I receive official notification/certification of my VPP status?
- I have completed the VPP process. How do I obtain my e-Profile ID for my pharmacy?
- How do I renew VPP or request another VPP inspection?
- What steps do I need to take in order to have an inspection for my Texas Class E-S license?
- What is the difference between VPP and VIPPS?
NABP E-Profile Assistance
1. Am I able to cancel my VPP application?
Per existing NABP refund policy, applications that are canceled or withdrawn by the applicant organization are subject to fees, including, without limitation, fees for administrative, travel, and staff resource costs incurred prior to the cancellation or withdrawal. Requests to cancel an application must be submitted in writing to VPP@nabp.pharmacy and are considered on a case-by-case basis.
2. How long will it take for my application to be processed?
Upon receipt of an online VPP application, NABP will review to determine completeness. This process may take approximately one to two weeks. If any documentation or clarification is necessary, NABP will inform you after this review. Once an application is determined complete, your pharmacy will be placed in the inspection queue and you may anticipate having an unannounced inspection at any point in time within approximately eight weeks. (Note: This time frame for inspection is an estimate and is subject to change pending inclement weather, a significant number of pharmacy black-out dates, or other unforeseen circumstances.) Upon completion of an inspection, an applicant may expect to receive the final completed inspection report electronically within 30 calendar days; however, on average, this time frame is less. The time may vary depending on the state of original licensure, whether discipline has ever been imposed on a license(s), the number of different nonresident pharmacy licenses an applicant currently holds, and the type of inspection necessary.
3. Does my pharmacy have to be licensed in the state of domicile for a year before I can obtain licensure in another state?
Please contact the board of pharmacy in the state in which you are seeking licensure for its specific state requirements.
4. Who notifies the Board that I have applied for nonresident licensure?
The VPP process and your nonresident licensure application are separate. You must contact your state board(s) of pharmacy directly to apply for a nonresident license. In addition, it is recommended that you also contact the board of pharmacy to confirm that a VPP inspection will suffice for any inspection requirements associated with that nonresident licensure application. Each state has individual requirements for nonresident licensure that may go beyond the VPP application. NABP will actively report licensee information, such as inspection and disciplinary action history as well as license verifications, from the facility e-Profiles to the state boards of pharmacy as an information resource for the boards to use when making licensing decisions.
5. What are the next steps after I’ve submitted a VPP application?
Upon receipt of the VPP application, NABP staff will contact applicants if there are questions regarding the application or if additional information is needed from the applicant. Once a VPP application is received and payment is processed, NABP will begin the review process. This includes a full review of the application to determine completeness, and verifying the pharmacy’s licensure information and history, including disciplinary actions and inspection history, as well as the licensure information of key personnel linked to the pharmacy. Once the application is deemed complete, NABP will also schedule an unannounced VPP inspection if a qualified inspection does not already exist.*
*NABP is working with the member boards of pharmacy to further define and finalize the criteria for an inspection to be determined as “qualified” for the purposes of VPP.
6. What if I have a change to my application?
If during the application evaluation process any information submitted on the VPP application changes, NABP must be notified in writing within 48 hours. Submit changes via email to VPP@nabp.pharmacy.
7. What if I need to place a hold on my unannounced inspection?
Prior to an inspection occurring, you may request to place your VPP application or inspection on hold at your expense for a period of not more than six months. The administrative fee to place a hold is $250 plus any additional costs incurred should an inspection already have been scheduled. If the pharmacy’s VPP application is placed on hold at the pharmacy’s request, the pharmacy agrees that a refund will not be issued.
8. What can I expect for the VPP uniform inspection?
After NABP has received a VPP application and payment, the pharmacy may be inspected at any time. The pharmacy is expected to be familiar with, and be operating under, all applicable regulations. The inspection is a snapshot in time.
As this is a general inspection, items may not be required by the state of residence. The VPP inspection gathers information and observes for compliance with USP Chapters <795> and <797>, as applicable. NABP does not make a determination of “passed” or “compliant” with regard to any specific state regulations. It is up to each individual state to determine compliance based on the findings of the VPP inspection.
The information and comments obtained in the nonsterile compounding and sterile compounding supplement inspections are based on USP Chapters <795> and <797>, respectively. An inspection against current Good Manufacturing Practices (cGMPs) is not conducted. Note: If your pharmacy is compounding, you will need to specify the hours during the day/week that your pharmacy performs compounding activities and also specify if the frequency is different. If you are a compounding pharmacy, the inspector will need to observe compounding activities in order to be able to adequately assess compliance. If an inspector arrives to inspect your pharmacy during your listed hours and your pharmacy is closed or you are not able to perform compounding activities, you will be charged for a second inspection.
For more information, please see the VPP Inspection Guidance Document.
Note: NABP is required to notify the resident state board of pharmacy that an inspection will be taking place in the state. The state board of pharmacy may choose to join the unannounced VPP inspection to observe.
9. What are the next steps after I’ve had a VPP inspection?
Upon completion of a VPP inspection, the inspection report will be sent back to NABP for internal quality assurance processing. The completed report will then be made available to all the state boards of pharmacy where a pharmacy is licensed, as well as those where a pharmacy is seeking licensure. This may take up to 30 calendar days from the time of the inspection; however, on average, this time frame is less. At this time, the pharmacy will also receive an electronic copy of the inspection report along with a cover letter detailing further instructions. The pharmacy then has the opportunity to provide a response to any of NABP’s findings listed in the report, which may include steps taken to correct any noncompliant items. It is the pharmacy’s responsibility to be compliant with all applicable state and federal rules, regulations, and laws. The pharmacy will need to provide NABP with this documentation, noting corrective action or an explanation of why a pharmacy need not remediate within 30 calendar days. (No responses will be received after that time and no extensions will be granted.) Upon receipt of this follow-up documentation, NABP will make this information available to all applicable state boards of pharmacy, as the state boards of pharmacy make all decisions regarding licensing and renewal. Compliance with a particular state’s regulations is determined by that state’s board of pharmacy. Questions about a particular state’s regulations should be addressed directly with that state.
The pharmacy is responsible for following up with the state board of pharmacy to ensure that all necessary steps have been taken for obtaining or renewing a license.
10. In what format should my responses to my completed inspection be submitted?
All response documentation must be received by NABP within 30 calendar days from the date the final inspection report is emailed to the pharmacy. No responses will be received after that time and no extensions will be granted. Responses must be submitted on the VPP Inspection Response Template. If you are including attachments, it is important that each page within the compiled electronic attachments be clearly identified, whether it is by attachment number or by title at the top of each page. Your response may include documentation or records that were not available to the inspector at the time of inspection, an explanation of items that are not required by your state of residence, and any steps you have taken or will take to remediate items not in compliance with your state.
11. Will I receive official notification/certification of my VPP status?
NABP does not make the final determination of licensure. NABP conducts a thorough survey, authentication of the pharmacy’s licenses, and validation of other information and provides this to the boards of pharmacy as verified data. NABP has been and continues to be in close discussions with the state boards of pharmacy to further develop VPP so that it meets their needs; however, it is still left to individual states receiving the inspection reports to make licensing/renewal decisions based on complete information and the verified data in the pharmacy’s VPP e-Profile. As more boards of pharmacy move toward recognizing VPP, some boards may request the NABP e-Profile ID for pharmacies in order to identify them in the VPP system. Please contact VPP@nabp.pharmacy to request your pharmacy’s e-Profile ID. For convenience, the e-Profile ID for the pharmacy is also viewable at the top right corner of the final VPP inspection report.
12. I have completed the VPP process. How do I obtain my e-Profile ID for my pharmacy?
Send an email to VPP@nabp.pharmacy requesting your pharmacy’s e-Profile ID. Include in the email the full pharmacy name and address in order to ensure that NABP is able to properly identify your pharmacy. You may also find the e-Profile ID for your pharmacy on the top right corner of the final VPP inspection report.
13. How do I renew VPP or request another VPP inspection?
NABP is working with the state boards of pharmacy to develop a uniform VPP policy as it relates to the frequency of inspection and the renewal requirements specific to the program. In the interim, all VPP participants are expected to understand the rules and regulations in the states where they hold licensure and maintain compliance with each state’s inspection requirements. Should a VPP pharmacy be required to have a more current inspection to renew or obtain a pharmacy license in a particular state, it is the pharmacy’s responsibility to proactively request an inspection from NABP. (Guidelines: If engaged in sterile compounding, request and undergo an annual inspection. If engaged in nonsterile compounding or general pharmacy practices only, request and undergo a biennial inspection.) As agreed to upon application to VPP, pharmacies are also responsible for providing updates to NABP relating to staffing, the pharmacist-in-charge, ownership, name changes, location changes, significant remodeling and/or equipment changes, etc, in order to ensure that the pharmacy e-Profile is up to date.
Should an existing VPP pharmacy require a new or more current inspection, NABP will work with that pharmacy to schedule and conduct a new unannounced inspection. To accomplish this, pharmacies can complete the online VPP application and submit directly to the Association along with the necessary fee. Upon receipt of this application, review, and confirmation that all information is complete, the pharmacy’s e-Profile will be reviewed and the pharmacy will be scheduled for an unannounced inspection within eight weeks. (Note: This time frame for inspection is an estimate and is subject to change pending inclement weather, a significant number of pharmacy black-out dates, or other unforeseen circumstances.)
It is important to note that it is always the pharmacy’s responsibility to apply for licensure and/or renewal of licensure directly with the state boards of pharmacy in addition to maintaining its records with the states where licensure is held. NABP continues to be in close discussions with the state boards of pharmacy to further develop VPP so that it meets their needs; however, it is still left to individual states receiving the inspection reports to make licensing/renewal decisions based on complete information and the verified data in the pharmacy’s VPP e-Profile.
14. What steps do I need to take in order to have an inspection for my Texas Class E-S license?
The Texas State Board of Pharmacy (TSBP) now requires that all nonresident pharmacies engaging in compounding sterile preparations obtain a Class E-S license in order to ship these preparations into the state of Texas. (Additional information regarding this requirement and the Texas license application can be found on the TSBP website.) As a component of this TSBP requirement, pharmacies must be inspected for compliance with TSBP Rule 291.133. NABP has been deemed an approved vendor to perform an inspection using the TSBP Class E (Nonresident) Inspection Report Relating to Compounding of Sterile Preparations form. In addition, TSBP recognizes the VPP Sterile Compounding Inspection Form as meeting this requirement. Please contact NABP for more information by emailing VPP@nabp.pharmacy or calling 847/391-4406 and asking to speak to a VPP representative.
15. What is the difference between VPP and VIPPS?
VPP and VIPPS (Verified Internet Pharmacy Practice Sites) are two separate programs offered by NABP. Some main points about each program are included below.
|Inspection and information sharing service||Accreditation|
|Snapshot in time of a pharmacy’s operations||Ongoing evaluation of a pharmacy|
|Inspection for compliance with USP 795 and 797 if compounding and of general pharmacy operations||Review of policies and procedures and survey of pharmacy to ensure in line with program criteria|
|Inspection report provided to pharmacy and state boards of pharmacy||Survey report not provided to pharmacy or state boards of pharmacy; however, post-survey letter is provided to pharmacy indicating items for remediation, if any, to bring pharmacy into compliance with program criteria and standards|
|NABP does not make final determinations of pharmacy compliance/approval. Review of documentation and determination of licensure/compliance left to the state boards of pharmacy||NABP provides accreditation and seal of approval provided to pharmacy|
1. What is an e-Profile?
The NABP e-Profile system allows individuals to easily manage their participation in NABP programs. At present, the system is used by pharmacists, pharmacy technicians, and pharmacy students to easily manage their participation in NABP programs and to track continuing pharmacy education. They are all provided with a unique e-Profile ID when they create their account.
Additionally, states may require facilities to provide e-Profile IDs so that they may access discipline and other information that is shared between states and managed by NABP in the e-Profile system. (See FAQ #2 below for information on obtaining a facility e-Profile ID.)
2. I am a facility, not an individual. How do I obtain an e-Profile ID?
At present, it is not possible for a facility to create its own e-Profile ID. However, NABP can assist your facility by creating the number, if necessary. It is possible that, unbeknownst to a facility, it may have already been assigned an e-Profile ID. If your facility has been VPP inspected, you may find the facility e-Profile ID on the top right hand corner of the VPP inspection report. If your facility has not been inspected through VPP, it is unlikely it will have its own NABP e-Profile ID. To determine if your facility either has an e-Profile or if NABP needs to create one on your facility’s behalf, please send the following information to email@example.com:
- Legal Business Name (typically filed with resident State’s Secretary of State)
- Doing Business as Name
- Facility Address
- NCPDP ID (if applicable)
- Resident State License Number