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Effective January 1, 2026, every nonresident pharmacy licensed by the Illinois Department of Financial and Professional Regulation (IDFPR) must designate a Pharmacist-in-Charge (PIC) who holds an active Illinois pharmacist license.
This new requirement appears in 68 Illinois Administrative Code § 1330.550(a):
"Beginning January 1, 2026, pharmacists-in-charge of
nonresident pharmacies shall be licensed in Illinois."
— 68 Ill. Adm. Code § 1330.550(a)
(Illinois Administrative Code – IDFPR)
Overview
Under Illinois law, a nonresident pharmacy is any
pharmacy located outside the state that ships, delivers,
dispenses, or distributes prescription drugs or devices
into Illinois.
(68 Ill. Adm. Code § 1330.10)
Nonresident pharmacies must register with the IDFPR and comply with
Illinois pharmacy rules. These include maintaining retrievable
prescription records for Illinois residents, providing a toll-free
telephone service for patient consultation, and disclosing
ownership and pharmacist information.
(68 Ill. Adm. Code § 1330.550)
Until now, Illinois did not require pharmacists employed by
nonresident pharmacies to hold Illinois licensure. The updated rule
changes that standard by requiring the
Pharmacist-in-Charge—the individual
responsible for ensuring compliance with Illinois pharmacy
law—to be licensed in Illinois beginning January 1, 2026.
Impact of the Change
The rule aligns Illinois with a growing number of states that
require in-state licensure for nonresident pharmacy PICs. It
ensures that the person accountable for operations affecting
Illinois patients is subject to Illinois regulatory authority and
understands state-specific requirements.
A nonresident pharmacy that does not have an Illinois-licensed PIC
in place by the effective date will be out of compliance with state
regulations and may face enforcement actions or renewal
delays.
Pharmacies should review their current PIC designations and confirm
that the designated pharmacist is licensed in Illinois prior to the
rule's effective date.
Summary
Beginning January 1, 2026, nonresident pharmacies licensed in Illinois must ensure their Pharmacist-in-Charge holds an Illinois pharmacist license. This rule, codified in 68 Ill. Adm. Code § 1330.550(a), creates a clear expectation of accountability and compliance for all pharmacies dispensing medications into Illinois. This new requirement ensures that the individual responsible for compliance and patient safety within these pharmacies is directly subject to Illinois regulations, aligning the state with a broader trend toward stricter oversight of out-of-state pharmacies operating within Illinois.
Pharmacies operating across state lines should proactively review and update their PIC designations to meet this new Illinois requirement. Ensuring that the designated PIC is licensed in Illinois not only guarantees compliance but also reinforces the pharmacy's commitment to patient safety and regulatory integrity. Staying ahead of these changes will help avoid potential enforcement actions and ensure seamless operations in the evolving landscape of pharmacy regulation.
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