Buying Medicine Online

Reasons for Placement on “Not Recommended” List

Internet drug outlets listed on the NABP Web site as Not Recommended are categorized as such for one or more of the following reasons:

1. Pharmacy Licensure.  The pharmacy is not licensed or registered in good standing to operate a pharmacy or engage in the practice of pharmacy in all required jurisdictions.
   
   
2. DEA registration. The pharmacy is dispensing controlled substances and is not registered with the US Drug Enforcement Administration (DEA).
   
   
3. Prior discipline. The pharmacy or its pharmacist-in-charge has been subject to significant recent and/or repeated disciplinary sanctions.
   
   
4. Pharmacy location. The pharmacy is not domiciled in the United States.
   
   
5. Validity of prescription. The pharmacy dispenses or offers to dispense prescription drugs without receipt of a valid prescription, as defined below, issued by a person authorized to prescribe under state law and, as applicable, federal law. The pharmacy distributes or offers to distribute prescriptions or prescription drugs solely on the basis of an online questionnaire or consultation without a pre-existing patient-prescriber relationship that has included a face-to-face physical examination, except as explicitly permitted under state telemedicine laws or regulations.
   
   
• Definition. A valid prescription is one issued pursuant to a legitimate patient-prescriber relationship, which requires the following to have been established: a) The patient has a legitimate medical complaint; b) A face-to-face physical examination adequate to establish the legitimacy of the medical complaint has been performed by the prescribing practitioner, or through a telemedicine practice approved by the appropriate practitioner board; and c) A logical connection exists between the medical complaint, the medical history, and the physical examination and the drug prescribed.
  
  
6. Legal compliance. The pharmacy does not comply with all provisions of federal and state law, including but not limited to the Federal Food, Drug, and Cosmetic Act and the Federal Controlled Substances Act (including the provisions of the Ryan Haight Online Pharmacy Consumer Protection Act, upon the effective date). The pharmacy dispenses or offers to dispense medications that have not been approved by the US Food and Drug Administration (FDA).
   
   
7. Privacy. The pharmacy Web site transmits information that would be considered Protected Health Information (PHI) under the HIPAA Privacy Rule (45 CFR 164), in violation of HIPAA requirements, which include the use of Secure-Socket Layer or equivalent technology for the transmission of PHI, or the pharmacy does not display a privacy policy that accords with the requirements of the HIPAA Privacy Rule.
   
   
8. Patient services. The pharmacy does not provide on the Web site an accurate US street address of the dispensing pharmacy or corporate headquarters. The pharmacy does not provide on the Web site an accurate, readily accessible and responsive phone number or secure mechanism via the Web site that would allow patients to contact or consult with a pharmacist regarding complaints or concerns or in the event of a possible adverse event involving their medication.
   
   
9. Web site transparency. The pharmacy engages in practices or extends offers on its Web site that may deceive or defraud patients as to any material detail regarding the pharmacy, pharmacy staff, prescription drugs, or financial transactions.
   
   
10. Domain name registration. The domain name registration information of the pharmacy is inaccurate, or the domain name registrant does not have a logical nexus to the dispensing pharmacy. Absent extenuating circumstances, pharmacy Web sites utilizing anonymous domain name registration services will be considered Not Recommended.
    
    
11. Affiliated Web sites. The pharmacy, Web site, pharmacy staff, domain name registrants, or any person or entity that exercises control over, or participates in, the pharmacy business is affiliated with or controls another Web site that violates these standards.
    

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