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Utah Authorizes AI-Based Prescription Renewals

Utah has issued a policy, through the Utah Department of Commerce and its Office of Artificial Intelligence Policy, authorizing a pilot program that allows an artificial intelligence (AI) system to autonomously renew certain...more

California Board Proposes Central Fill Amendments That Clarify (but Limit) Shared Service Models in the State

The California State Board of Pharmacy (the “Board”) has proposed amendments to its rule regulating central fill pharmacies, Cal. Code Reg. tit. 16, § 1707.4, through a recent Notice of Proposed Action. The comment period is...more

Back to Square One: Mississippi Board of Pharmacy Reaffirms Ban on Shared Pharmacy Services

Today, the Mississippi Board of Pharmacy (“Board”) issued a notice to licensees confirming that its rulemaking process on shared pharmacy services has concluded, and that no changes have been made to the state’s current...more

New York Publishes Proposed Rule Regarding Pharmacy Shared Services Arrangements

On September 24, 2025, the New York Education Department published a Proposed Rule addressing shared pharmacy services. The Proposed Rule conforms the state pharmacy regulations with the recent statutory changes that permit...more

California Enacts Sweeping Pharmacy Bill Extending Board Sunset and Requiring Nonresident PIC Licensure

On October 1, 2025, Governor Gavin Newsom signed into law AB 1503, creating wide-ranging changes for the world of pharmacy inside and outside California. The new legislation affects pharmacy operations, nonresident pharmacy...more

Puerto Rico Repeals Special Authorization Requirement for Nonresident Manufacturers and Distributors

In July 2022, the agency formerly known as the Puerto Rico Auxiliary Secretariat for Regulation and Accreditation of Health Facilities (SARAFS), now the Auxiliary Secretariat for the Regulation of Public Health (SARSP),...more

Indiana Senate Bill 140 Signed into Law Imposing Reforms on Pharmacy Benefit Managers

Indiana recently enacted significant new legislation that will impact how pharmacy benefit management services are provided in Indiana. Senate Bill 140 (SB 140), signed into law during the 2025 legislative session, imposes...more

Part D Pharmacies Required to Enroll in Data Exchange Module to Help Drug Price Negotiation Cash Flow Issue

On April 15, 2025, the Centers for Medicare & Medicaid Services (“CMS”) published the Contract Year 2026 Policy and Technical Changes Final Rule which amends the regulations governing various Medicare programs, including the...more

“It’s Okay, These Products Aren’t Paid for by Medicare” – Think Again

A recent Securities and Exchange Commission (“SEC”) settlement with DMK Pharmaceuticals Corporation (“DMK Pharmaceuticals”) and its Chief Financial Officer (“CFO”) serves as a good reminder that SEC-regulated entities...more

Missouri’s New Year Resolution: New Prescription Delivery Requirements for Mail Order Pharmacies

Effective December 30, 2024, significant revisions to the Missouri Board of Pharmacy’s Rule 20 CSR 2220-2.013 (Prescription Delivery Requirements) will kick in, introducing new patient safety measures for pharmacies that mail...more

FDA Releases Declaratory Order Regarding Tirzepatide Shortage

The FDA released a Declaratory Order on December 19th re-evaluating and essentially re-instituting its previous position on the tirzepatide shortage, declaring the shortage resolved. As a bit of history, on October 2, 2024...more

New York Passes Much-Anticipated Law Authorizing Pharmacy Shared Services Arrangements

On November 22, 2024, the Governor of New York signed into law a closely watched bill that expressly authorizes pharmacy shared services arrangements in the state. These models were not previously addressed in New York’s...more

Are You Ready for Massachusetts Non-Resident Pharmacy Licensure?

On November 19, 2024, the Massachusetts Board of Registration in Pharmacy (the “Board”) published several memoranda that described the impending non-resident pharmacy licensure requirements and the anticipated timeline for...more

FDA Issues Broad Exemptions from DSCSA Enhanced Drug Distribution Security Requirements

On October 9, 2024, the Food and Drug Administration (“FDA”) issued a document that provides exemptions to the enhanced drug distribution security requirements (enhanced requirements) required by section 582(g) of the Food,...more

DEA Issues New Regulation Formalizing Black Bag Exception for Veterinarians

The Drug Enforcement Administration (DEA) recently issued a new regulation codifying provisions of the Veterinary Medicine Mobility Act of 2014 (VMMA). The VMMA, which was signed into law in 2014, allows a veterinarian to...more

FDA Releases Draft Interim Guidance on Bulk Drug Substances in Compounding Under Sections 503A and 503B of FDCA

The Food and Drug Administration (“FDA”) has released draft interim guidance documents that impact the use of bulk drug substances in compounding under Sections 503A and 503B of the Federal Food, Drug, and Cosmetic Act...more

Are You Ready for Alabama’s New Designated Representative Requirements?

In a previous update, Quarles discussed a new Alabama law that requires individuals serving as the designated representative for an Alabama-licensed facility to register with the Alabama Board of Pharmacy ("the Board”) as of...more

New California Law Affects Pharmacy Operations, Staffing Ratios, And Much More

On October 8, 2023, California Governor Gavin Newsom signed Assembly Bill 1286 into law. The new law, sponsored by Assemblymember Matt Haney and the California Board of Pharmacy, aims to reduce medication errors and...more

Florida Board of Pharmacy Proposes Amendments to Rule on Technician to Pharmacist Ratio

On September 12, 2023, the Florida Board of Pharmacy published a notice of intent to adopt amendments to its rule on registered pharmacy technician-to-pharmacist ratios (64B16-27.410). The amendments would allow a supervising...more

More Guidance Released from FDA for Drug Supply Chain Security Act Compliance

The Food and Drug Administration (“FDA”) released additional guidance documents on Wednesday, August 30th pertaining to the enhanced drug distribution security requirements under the Drug Supply Chain Security Act (“DSCSA”). ...more

Oklahoma Patient's Right to Pharmacy Choice Act Preempted by ERISA

On August 15, 2023, the U.S. Court of Appeals for the Tenth Circuit issued an opinion in Pharmaceutical Care Management Association v. Glen Mulready, in his official capacity as Insurance Commissioner of Oklahoma, Oklahoma...more

Drug Supply Chain Security Act Compliance Extended But Trading Partners Should Still Prepare Now

On Friday, August 25th, the Food and Drug Administration (“FDA”) issued a guidance document extending the November 27, 2023 enforcement deadline for drug and device manufacturers, wholesale distributors, dispensers, and...more

FDA Announces Guidance for DSCSA Process to Request a Waiver, Exception, or Exemption

On Friday, August 4th, the Food and Drug Administration (“FDA”) announced the availability of a final guidance document, titled “Waivers, Exceptions, and Exemptions From the Requirements of Section 582 of the Federal Food,...more

FDA Announces Draft Guidance on Outsourcing Facility Sales

The U.S. Food and Drug Administration (FDA) issued a draft guidance document, June 27, that describes FDA’s current thinking on the prohibition of wholesaling human drugs by a 503B outsourcing facility under the Food, Drugs,...more

Nevada Legislature Rejects Board of Pharmacy’s Licensing Requirement for Out-of-State Pharmacists

On May 31, 2023, the Nevada Legislature enacted Assembly Bill 107, which reversed the Nevada Board of Pharmacy’s (the “Board”) interpretation that required Nevada pharmacist licensure for out-of-state pharmacists who dispense...more

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