Shared Pharmacy Services

Late in the 2024 legislative session New York enacted a process that will allow a dispensing pharmacy to have prescriptions processed by a cooperating pharmacy under a “shared” services arrangement.[1] The dispensing pharmacy forwards a copy of the prescription to the shared service pharmacy, which then processes, labels, and returns the finished prescription to the originating pharmacy that will then dispense to the patient. Many states have passed such laws recently, and New York’s is consistent with the “Central Fill” guidelines for controlled substances established by federal DEA[2] with one exception: the DEA requirement of returning the finished prescription to the dispensing pharmacy for delivery to the patient. The new law also provides for registration of a non-resident shared services provider (see §6808-b, below).

The cooperating pharmacies must be under common ownership or have a formal written contract defining the relationship. The shared pharmacy requires electronic access to patient information, a system for tracking each prescription, a label that identifies both pharmacies, and management of controlled substances consistent with NY law. Notice to patients through signage and a one-time consent from each patient; option to opt out at any time. Each participating pharmacy must have policies and procedures covering every aspect of the relationship including processing, transportation, storage, and security of medication and personal health information. Note that the law specifically provides for processing information from a location outside of the participating pharmacy. This new law has an implementation date of May 22, 2026. The Commissioner of Education has proposed regulations (new §63.18) that will likely be finalized before the implementation date.

[1] 2024 Laws of NY, Ch. 491.
[2] Pharmacist’s Manual 2022, DEA, p. 75.

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