Buffalo Pharmacy Law Newsletter.

Spring 2026

Pharmacy Law is a newsletter from the University at Buffalo School of Pharmacy and Pharmaceutical Sciences covering pharmacy practice laws in New York State.

From the Editor

Pharmacy Law has a proud history at UB — begun in 1993 by the late Robert M. Cooper, PharmD, the newsletter was later carried forward for 25 years by Karl Fiebelkorn, BS '78, MBA '88, RPh, whose law updates helped generations of pharmacists and students stay current. I am honored to continue that tradition.

This inaugural issue covers recent legislative and regulatory developments in New York — from emergency dispensing for opioid use disorder and expanded technician compounding authority to pharmacist-dispensed contraceptives, prescription labeling protections, and New York's new Medical Assistance in Dying Act.

Whether you are preparing for the upcoming MPJE or navigating practice in a rapidly changing landscape, I hope you find it useful.

Karl Williams, JD, MBA, BS '80
Clinical Professor and Director of Professional Affairs
Editor, Pharmacy Law
UB School of Pharmacy and Pharmaceutical Sciences

Karl Williams, JD, MBA, BS '80.

Karl Williams, JD, MBA, BS '80

In this issue:

Emergency Dispensing for Harm Reduction

New York has taken a significant step in addressing the opioid crisis by amending its Controlled Substances Act to align with longstanding but underutilized federal flexibility. Effective Feb. 19, 2026, the law now permits institutional dispensers to provide up to a three-day supply of controlled substances as emergency treatment for opioid use disorder—a practice previously barred under state law for more than 50 years. For pharmacists in hospital and emergency department settings, the change brings both new authority and new workflow responsibilities. This article examines the regulatory history behind the law and what it means for practitioners. 

Technician Parity for Compounding

A 2025 amendment to New York's pharmacy technician law has resolved a long-standing competitive inequity: registered pharmacy technicians may now assist in extemporaneous compounding at any pharmacy in the state, not just in hospital settings. The change closes a gap that had existed since the profession was created in 2019 — one that placed community and home infusion pharmacies at a disadvantage relative to hospital pharmacies. This article traces the legal and regulatory history behind the limitation, from the 1991 Sheffield decision through the legislative response, and explains what the expanded authority means for pharmacists supervising technicians today.

Pharmacist-Dispensed Contraceptives

Since March 2024, New York pharmacists have had authority to dispense self-administered hormonal contraceptives pursuant to a statewide standing order — part of a national trend now adopted by 38 states. The law establishes specific requirements for pharmacist training, patient screening, prescriber notification, and recordkeeping, while New York Medicaid provides coverage for the service. This article surveys the statutory and regulatory framework governing pharmacist-dispensed contraceptives in New York, with attention to scope of practice, workflow obligations, and pending legislation that would expand authority to injectable products.

Legislative Briefs

  • Labeling Mifepristone and Misoprostol: Two bills enacted in early 2025 amend New York's pharmacy practice law to allow dispensing pharmacies to substitute practice-level contact information for a prescriber's personal details on the label — shielding practitioners from civil and criminal exposure in states that have outlawed use of these medications to terminate pregnancy.
    Read the full brief: Labeling Mifepristone and Misoprostol
  • Notice of Closing: Effective Feb. 10, 2026, New York pharmacies must provide patients and conspicuous in-store notice at least 30 days before permanent closure, with failure to comply potentially constituting a misdemeanor and grounds for professional misconduct charges. 
    ➔ Read the full brief: Notice of Closing
  • Shared Pharmacy Services: A 2024 law — with an implementation date of May 22, 2026 — establishes a framework permitting a dispensing pharmacy to forward prescriptions to a cooperating pharmacy for processing, labeling, and return, provided the pharmacies share common ownership or a formal written contract. 
    ➔ Read the full brief: Shared Pharmacy Services
  • Medical Assistance in Dying: Signed into law Feb. 6, 2026, and effective Aug. 5, 2026, New York's Medical Assistance in Dying Act permits physicians to provide qualifying terminally ill patients with medication sufficient to end their life, with a conscientious objection provision that expressly covers pharmacists and requires no stated justification.
    Read the full brief: Medical Assistance in Dying

Regulatory Briefs

  • Transfer of Refills: A 2025 amendment to New York's pharmacy transfer regulations now permits all remaining refills to be transferred with a prescription — not just one at a time — bringing state practice closer to federal DEA rules, though an open question remains as to whether controlled substance refill transfers are explicitly authorized under New York law.
    ➔ Read the full brief: Transfer of Refills 
  • Long-acting Injections: Regulations in effect since April 1, 2024 authorize pharmacists and supervised interns to administer FDA-approved long-acting injectable medications for substance use disorder and mental health conditions, subject to immunization training certification, prior prescriber administration of the first dose, informed consent, and reporting requirements.
    ➔ Read the full brief: Long-acting Injections

Case Law

Corresponding Responsibility, Red Flags, and Independent Pharmacy in Federal Court

A federal appeals court has overturned the DEA's revocation of a Louisiana pharmacy's controlled substance registration, holding that the agency must prove prescriptions were actually invalid — not merely that the pharmacist had reason to question them. The implications for pharmacists practicing in New York remain unsettled. Read the case law: Case Law: Corresponding Responsibility, Red Flags, and Independent Pharmacy in Federal Court

Copyright © 2026 University at Buffalo. All rights reserved. 

Pharmacy Law is published as an educational service to the pharmacy community in New York State. Its sole purpose is to promote an understanding of the laws, rules, and regulations that affect the practice of pharmacy in New York. The advisory board, authors and the University at Buffalo do not hold themselves out as offering legal advice. Readers should seek counsel for specific legal questions or concerns.