Reverse Distribution: Serving Public Health Under Range of State Rules

In the Jan. 2022 edition of the National Association of Boards of Pharmacy’s (NABP) Innovations publication, government and regulatory affairs partner Libby Baney, insurance partner Jay Warmuth and health care associate Jonathan Keller, PharmD, co-authored an article on the importance of reverse distribution in the supply chain system and related regulations.

The authors emphasize how the handling and removal of pharmaceutical products is a substantial public health matter and worth examining from a regulatory context. However, due to how regulations vary among states, guidance can be inconsistent for reverse distributors. They further explain the reverse distribution process, regulatory common ground and the landscape of state licensing requirements. 

The authors also discuss the added complexity regarding the reverse distribution of controlled substances. In conclusion, they share several questions that boards of pharmacy may want to consider when developing regulations, policies or statutory language.

An expanded version of this article was published by the Food and Drug Law Institute.