A Roadmap to Dispenser DSCSA Readiness
Justin Macy, PharmD, JD, and Andrew Funk, PharmD, of NABP, emphasize that compliance is a critical safeguard against the rising threat of counterfeit and illegitimate products.
As the final implementation milestone for the Drug Supply Chain Security Act (DSCSA) approaches this November, small dispensers—those with fewer than 25 full-time employees—must finalize their transition into a fully interoperable digital supply chain.
To provide valuable insight on final DSCSA implementation, Justin Macy, PharmD, JD, and Andrew Funk, PharmD, from the National Association of Boards of Pharmacy (NABP), joined the Total Pharmacy Solutions Summit Summer 2026 event.
Central to this new era, according to the experts, is the mandate to transact only with authorized trading partners, which requires pharmacies to verify that every wholesaler and manufacturer holds valid state licensure and FDA registration.
The industry is shifting from lot-level tracking to a serialized model where every individual bottle is a unique entity with data that must be stored for 6 years. This granular tracking is designed to address “red flags” such as unsolicited sales offers or unusual packaging, which have recently been linked to counterfeit GLP-1s and dangerous patient buyback schemes.
When a product is identified as suspect, pharmacies are legally required to quarantine the item and conduct a formal investigation, which includes performing product verification with the manufacturer. If a product is confirmed as illegitimate, the FDA must be notified via Form 3911 within 24 hours.
Regulators are signaling that adherence to updated policies and procedures will be a primary focus during future inspections. To ease this transition, NABP is launching Pulse, a platform providing dispensers with free access to communication tools and product verification solutions.
By integrating these digital tools and formalizing internal workflows now, pharmacies can secure their operations and protect community health before the final regulatory deadline.
Explore more of our coverage from the Total Pharmacy Solutions Summit Summer 2026: Policy, People, and Profitability.
