Frequently Asked Questions
The Board receives frequent questions from pharmacists, consumers, and other health care professionals concerning laws and regulations related to the lawful possession, administration, dispensing, distribution, delivery, prescribing, and other disposition of prescription drugs in Virginia. Answers to some of the most frequently asked questions will be posted here for your convenience, so keep checking back here as we build Pharmacy's FAQ content. Please feel free to send your suggested FAQ for posting to firstname.lastname@example.org.
Questions Related to Pharmacist Licensing
Where may an individual having completed an ACPE-approved school of pharmacy find information on how to obtain a pharmacist license in Virginia?
Please refer to Guidance Document 110-2 for information on obtaining a pharmacist license by examination, or by reciprocity from another state, also called "licensure by endorsement" or "license transfer".
What are the requirements for a graduate of a foreign school of pharmacy to become licensed in Virginia?
Please refer to Guidance Document 110-17 for more complete information on eligibility for a graduate of a foreign college of pharmacy to become licensed as a pharmacist in Virginia. Prior to application as a pharmacy intern for the purpose of obtaining practical experience and prior to application for a pharmacist license, a graduate of a foreign school of pharmacy must first complete the Foreign Pharmacy Graduate Equivalency Committee certification process (FPGEC). which includes an education equivalency review and approval, passage of the FPGEE and a passing score on the TOEFL-iBT, or both the TOEFL and TSE. More information on this process is on the National Association of Boards of Pharmacy website at www.nabp.net
The Virginia Board of Pharmacy has no authority to waive the requirements for the FPGEC and does not approve any alternative educational credentials or alternative tests. Please do not contact the Board to request an exception to the FPGEC requirements.
Does Virginia require the FPGEC for graduates of Canadian colleges of pharmacy?
In accordance with the ACPE recognition of accreditation by the Canadian Council for Accreditation of Pharmacy Programs (CCAPP), with respect to professional programs leading to the baccalaureate degree in pharmacy for the time period since the establishment of CCAPP in 1993 through June 30, 2004, Virginia will also deem these programs equivalent and not require the FPGEC for those persons graduating from a CCAPP accredited college of pharmacy during this time period only. Persons graduating prior to 1993 or after June 30, 2004 must obtain the FPGEC.
Does Virginia require the tests of written and spoken English for applicants from foreign colleges of pharmacy where English is the primary language in that country, such as the United Kingdom and parts of Canada?
The Board has no authority to waive the requirements for the tests of English for those persons graduating from a foreign college of pharmacy even if English is the primary language.
How does a pharmacist currently licensed in another state reciprocate his license to Virginia?
A pharmacist must first complete the licensure transfer application process through the National Association of Boards of Pharmacy (NABP) by visiting www.nabp.net .A review of his educational credentials and licensure status, to include any possible disciplinary action, will be performed to ensure compliance with Virginia's requirements. Once this application to NABP has been approved, NABP will provide the pharmacist with a partially-completed NABP Official Application For Transfer of Pharmacist License to the state of Virginia. The pharmacist must then fully complete this application and submit it to the Virginia Board of Pharmacy. Once the Board reviews and approves this application, provided no grounds exist to deny the license, the Board will notify the pharmacist of his eligibility to sit for the Virginia Federal and State Drug Law Examination (FSDLE). Virginia does not participate in the Multistate Pharmacy Jurisprudence Examination (MPJE).
More information regarding this process may be found in Guidance Document 110-2. Additionally, the study guide for the Virginia Federal and State Drug Law Examination (FSDLE) should be carefully reviewed, along with the laws and regulations specified in the guide before attempting to take this examination. Many applicants have found the examination difficult to pass without studying. An applicant should not rely on his assumed knowledge of pharmacy law to pass this examination, especially if practicing in another state, as state laws may differ significantly.
Does Virginia allow reciprocity with Florida?
Virginia allows any pharmacist who holds a current and unrestricted license in another state, including Florida, to be licensed in Virginia provided that pharmacist meets all Virginia requirements for licensure by examination including a passing score on the national licensing examination developed by the National Association of Boards of Pharmacy (NABP) and on Virginia's law examination, and provided no grounds exist to deny the license.
Does Virginia participate in NABP's score transfer program for transfer of NAPLEX scores when the examination is taken in another state?
Yes. For details refer to NABP's NAPLEX registration bulletin.
How many practical experience hours are required in Virginia prior to applying for a license?
An applicant for licensure as a pharmacist shall attain a minimum of 1,500 hours of practical experience. Practical experience that is gained within an ACPE-accredited school of pharmacy, that conforms to the current ACPE standards, and that allows the student to gain at least 1,500 hours of practical experience, shall meet the board's practical experience requirements for licensure as a pharmacist. Virginia no longer requires 300 hours of the 1,500 hours of the practical experience to be gained outside the college of pharmacy experiential program. Reference: Regulation 18VAC110-20-30
How does an applicant register for the Virginia Federal and State Drug Law Examination (FSDLE)?
Once an applicant has been notified by the Board that he is eligible to sit for the Virginia Federal and State Drug Law Examination (FSDLE), he may register and find a preferred testing center location by visiting Iso-Quality Testing’s (IQT) website at www.isoqualitytesting.com or by calling their toll free number 866-773-1114. At the time of registration he will be asked a series of questions:
- When – The day and time he wishes to take the exam.
- Where – The location of the Testing Center.
- Payment – He may be able to pay the $112 Testing Fee with a personal credit card over the phone or he may contact Iso-Quality Testing for other means of payment.
- Full Legal Name – His official name on record given to the Virginia Board of Pharmacy.
- Social Security number or Virginia DMV control number – This is his personal identification number that will be used by both the Virginia Board of Pharmacy and Iso- Quality Testing.
More specific information regarding the registration process for this exam may be found in the Study Guide (Examination Handbook) for Virginia Federal and State Drug Law Exam (Word .doc)
Does an applicant have to travel to Virginia to take the Federal and State Drug Law Examination (FSDLE)?
No. This computer-based examination is administered at testing sites throughout the United States. Please visit Iso-Quality Testing’s (IQT) website at www.isoqualitytesting.com or call their toll free number 866-773-1114 to find a preferred testing center location.
Are there sample questions or a preparatory class offered for the Virginia Federal and State Drug Law Examination (FSDLE)?
No. However, applicants are strongly encouraged to use the Study Guide (Examination Handbook) for Virginia Federal and State Drug Law Exam (Word .doc) as a study guide when preparing to take this exam.
What is the benefit of having an inactive license?
If a pharmacist does not plan to practice pharmacy in Virginia, taking inactive status will cost less in renewal fee and the pharmacist does not have to obtain 15 hours continuing education (CE) each year. If a pharmacist decides to reactivate an inactive license, he or she will need pay the difference between the active and inactive fee and to obtain the amount of CE that would have been required during that time period up to a maximum of 60 hours total. However, the hours may be obtained at any time between the date inactive status is taken and the date of reactivation. For example, if a pharmacist has been inactive for 3 years, 45 hours of CE is due to reactivate, but all 45 hours may have been obtained the week prior to the reactivation request, rather than 15 hours dated within each year. One problem with inactive status, is that pharmacists who have been inactive for more than 5 years, and then want to reactivate, must take and pass the Virginia pharmacy law examination again, and if they cannot provide documentation that they have been practicing in another jurisdiction, must also perform 160 hours as a pharmacy intern in order to be eligible to reactivate.
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Questions Related to Facility Licensing
Does the Board provide advice or review plans related to the construction of a new pharmacy or the remodeling of an existing pharmacy?
The Board does not give construction advice other than the requirements listed in regulations, nor does it review and approve plans. Application is required for any new pharmacy or for any remodeling or change of location of an existing pharmacy. Current regulations must be met in any new construction and the new construction must be inspected prior to stocking prescription drugs. Reference: Law- §54.1-3434 and Regulation- 18 VAC 110-20-110 through 200
How many days notice need to be given on closing of a pharmacy?
A pharmacy owner may provide notice to the public in one of two ways. A sign may be conspicuously posted at least 30 days prior to closing or a notice may be mailed to all active refill customers at least 14 days prior to closing. Such notice shall include the expected date of closing, and the name of the pharmacy to which prescriptions and other records will be transferred. In addition, a notice must be provided to the Board at least 14 days prior to closing giving the information provided to the public, an explanation as to how the public notice was given (if by mail, send in a copy of the notice showing date), and notification as to where drugs will be transferred. Reference: Law- §54.1-3434.01 and Regulation- 18 VAC 110-20-130
I need a copy of the Drug Control Act and the pharmacy regulations.
Both are available on this website under Laws and Regulations Reference: N/A
What is the earliest date that the Board will schedule an inspection once an application has been submitted for a new permit, a change of location or for the remodeling of a pharmacy?
Board regulation 18VAC110-20-140 states that applications submitted to the Board which indicate a requested inspection date, or requests which are received after the application is filed, shall be honored provided a 14-day notice is allowed prior to the requested inspection date. Occasionally, the inspectors may be able to accommodate an earlier date, but this is dependent on their previously scheduled obligations. Additionally, please note that if the applicant needs to reschedule a previously agreed upon inspection date due to construction delays, vacations, etc. then this may result in
an additional delay of 14 days depending upon the inspectors' prior commitments.
Does an out-of-state supplier of medical equipment and supplies need a Virginia permit in order to be reimbursed by Medicaid?
Virginia law restricts the dispensing of prescription devices and oxygen, sterile water and saline, and hypodermic needles and syringes to either a permitted pharmacy or a permitted medical equipment supplier, therefore, the Department of Medical Assistance Services (DMAS) which administers the Medicaid program in Virginia usually requires proof of Virginia licensure in order for a company to be credentialed as a Medicaid provider. The application for a medical equipment supplier or for a non-resident pharmacy can be downloaded from the forms section of this web page. Reference: Law- §§54.1-3401, 54.1-3434.1, and 54.1-3435.2
Does an out-of-state pharmacy need to be registered in Virginia in order to be reimbursed by Medicaid?
If the out-of-state pharmacy is shipping, mailing, or otherwise delivering prescription drugs into Virginia to Virginia residents, registration as a non-resident pharmacy is required. However, if the out-of-state pharmacy is not mailing, shipping, or delivering into Virginia and is only dispensing to Virginia residents who come into the pharmacy to have prescriptions filled, Virginia law does not require registration. The Department of Medical Assistance Services (DMAS) which administers the Medicaid program in Virginia may ask for documentation of Virginia registration as part of the credentialing process to be a Medicaid provider since is has no way of determining if a claim is the result of a mail-order prescription or a walk-in prescription. According to DMAS officials, in lieu of providing a non-resident pharmacy registration, an out-of-state pharmacy may certify to DMAS in writing that it is not a mail-order pharmacy and only fills "walk-in" prescriptions. Proximity of the pharmacy to the Virginia border may also be requested by DMAS. Reference: Law- §54.1-3434.1
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Questions Related to Pharmacy Practice
If a pharmacist is not physically present in the prescription department (helping a patient, taking a break, etc.), does the prescription department have to be locked and alarmed?
No one can be present in the prescription department of a pharmacy, and that prescription department must be locked and alarmed, unless a pharmacist is on duty. The term "on duty" as defined in 18 VAC 110-20-10 means that a pharmacist is on the premises at the address of the permitted pharmacy and is available as needed. Further, 18 VAC 110-20-190 (C) provides the pharmacist on duty the discretion to at all times authorize persons to be present in the prescription department or to disallow any person to be in the prescription department.
Can a pharmacy set up an answering machine or voice-mail for prescribers and their authorized agents to leave oral prescriptions or refill authorizations?
Yes, the Board recently considered this issue and determined that an oral prescription may be left by a prescriber on a voice recording device or on voice mail provided the pharmacist personally takes the prescription information off the recorder or voice mail and transcribes the oral prescription to a written hard copy. Reference: Board Minutes, 6/11/98
Can a pharmacy return dispensed prescriptions from "will call" to stock if the patient never picks up the prescription?
Yes. Regulation 18VAC110-20-355 D allows the restocking of drugs from will-call provided the pharmacy places an expiration date on the label which in the absence of stability data to the contrary, shall not exceed the expiration date on the manufacturer's container or one year from the date the drug was originally dispensed, whichever date is earlier. The restocked drug should be used to fill the next prescription received for that product. In the event that the drug is not dispensed prior to the new assigned expiration date, it shall be removed from stock and destroyed or otherwise disposed of in accordance with regulations. If there is no lot number on the label of a drug returned to stock or on the prescription records which can be cross referenced from the prescription label, the drug will be removed from stock upon any recall of that drug product and returned to the manufacturer or otherwise disposed of in accordance with regulations. Reference: Regulation 18VAC110-20-355
What changes does DEA allow a pharmacist to make to a prescription written for a CII controlled substance?
What changes does DEA allow a pharmacist to make to a prescription written for a CIII-V controlled substance?
If a prescription is dispensed in multiple containers, for example at a parent's request to have an extra container to send to school, how must the prescription be labeled? May only the school instructions be placed on the school container?
All containers should be labeled with the same instructions and must reflect the prescriber's complete instructions. Reference: Minutes-June 10, 1997, §54.1-3410 (A)(3) and (B)(2), §54.1-3463 (A)
What is a Board approved innovative (pilot) program?
As explained in §54.1-3307.2, any person who proposes to use a process or procedure related to the dispensing of drugs or devices or to the practice of pharmacy not specifically authorized by Chapter 33 (§ 54.1-3300 et seq.) of this title or by a regulation of the Board of Pharmacy may apply to the Board for approval to use such process or procedure. The submitted application may only contain suggested processes or procedures which are within the current scope of the practice of pharmacy, that relate to the form or format of prescriptions, the manner of transmitting prescriptions or prescription information, the manner of required record keeping, the use of unlicensed ancillary personnel in the dispensing process, and the use of new technologies in the dispensing process. An innovative (pilot) program shall not expand the current scope of practice of pharmacists. The Board may choose to deny the proposed program, approve the program as submitted, or approve the program based on specific terms and conditions. For more information regarding innovative (pilot) programs or for a copy of a Consent Order related to an innovative program, please contact the Board office directly. Reference: §54.1-3307.2 and 18VAC110-20-121
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Questions Related to Pharmacy Technician Registration
What are the prerequisites for being eligible for registration?
There are two methods for obtaining registration as a pharmacy technician. Either of the following methods is acceptable.
- If an individual holds current certification from the Pharmacy Technician Certification Board (PTCB), then he may submit the online Application for Registration as a Pharmacy Technician to the Board for review. Information regarding obtaining certification from PTCB may be accessed at www.ptcb.org and the Board’s online application may be accessed at www.license.dhp.virginia.gov/apply/ .
- An individual must satisfactorily complete a Virginia Board of Pharmacy approved training program, pass a Board of Pharmacy approved examination, and then submit the online Application for Registration as a Pharmacy Technician to the Board for review. There are many Board approved pharmacy technician training programs from which to choose. A complete list may be found by here. Additionally, there are currently two Board approved examinations. An individual may either take and pass the Virginia Pharmacy Technician Exam or the ExCPT exam. Information for the Virginia Pharmacy Technician Exam may be accessed at www.smttest.com/vapt and information for the ExCPT exam may be accessed at www.nhanow.com
Where can I get an application form?
The paper application for registration as a pharmacy technician has been replaced with an online application. The online application may be accessed on our website at www.license.dhp.virginia.gov/apply/ .
What is the fee for registration?
A person who wishes to register as a pharmacy technician must submit a completed application and a $25 fee to the Board of Pharmacy. Checks are to be made payable to the “Treasurer of Virginia”. The application will usually be reviewed and verified, and processed within 7 to 10 business days. A pharmacy technician must maintain their registration in order to continue performing technician tasks. This requires a $25 annual renewal fee and the completion of 5 hours of pharmacy continuing education annually.
How do I know if the board has approved a training program?
Approved training programs may be identified by checking our website for a listing. Click on the “Technicians” link then on “List of Approved Pharmacy Technician Training Programs.” A person who has completed a training program prior to board approval need not retake the entire program after it is approved provided there have been no significant changes in the program or provided the person receives additional training on the portion that has been changed.
How do I sign up for the Virginia examination?
Visit the SMT (current exam vendor) website at http://www.smttest.com/vapt to locate a testing site near you and make a test reservation.
Where may I learn more about the Virginia Pharmacy Technician exam?
Visit the SMT (current exam vendor) website at http://www.smttest.com/vapt for complete information regarding testing sites, test reservations, frequently asked questions specific to this exam, study guide, self-assessment questions, and more.
Where may I learn more on how to register for the ExCPT exam?
For complete information regarding the ExCPT exam, please visit the ICPT website at www.nhanow.com.
How do I request to take the PTCB test?
Information about applying to take the PTCB can be found at www.ptcb.org .
What is the cost for taking the Virginia Pharmacy Technician Examination, ExCPT examination, and PTCB examination?
As of January 1, 2009, the cost for the Virginia examination is $75.50. Current fee information for the ExCPT examination and PTCB examination may be obtained from visiting their websites at www.nhanow.com and www.ptcb.org. respectively.
Do persons newly hired to be pharmacy technicians have a “grace period” before they need to be registered with the Board of Pharmacy?
Provided a person is enrolled in an approved pharmacy technician training program, that person can work as a pharmacy technician for up to nine months while going through the process to become registered. After the nine months, registration is required in order to continue working as a pharmacy technician. Every pharmacy using such a person shall have documentation on site and available for inspection showing that the person is currently enrolled in an approved training program, and the start date for the training. Reference: Regulation 18VAC110-20-111
May I work in a pharmacy as a technician if I plan to take the PTCB exam in the future?
Applying to take the PTCB is not considered to be enrollment in a Board approved training program. You may not work as a pharmacy technician unless you are registered or enrolled in a Board approved training program (see above). If you want to work while waiting to take the PTCB, you must be enrolled in an approved program.
What are the requirements for continuing education?
Registered Pharmacy Technicians are required to obtain a minimum of 5 contact hours of continuing pharmacy education (CPE) per calendar year in order to maintain an active registration. This brochure is intended to help pharmacy technicians to better understand the CPE requirements. The Board of Pharmacy prepared this document as a guide in order to promote compliance with the statutes and regulations concerning CPE.