Vet-VIPPS Criteria and Standards

Pharmacies conducting pharmacy services over the Internet and other businesses or persons conducting drug-related services over the Internet must meet the following criteria and standards to earn Vet-VIPPS accreditation.

Vet-VIPPS Criteria

Licensure and Policy Maintenance

Qualifying Vet-VIPPS Pharmacies must:

  1. provide NABP with the information necessary to verify that the Vet-VIPPS pharmacy is licensed or registered in good standing to operate a pharmacy and/or engage in the practice of pharmacy with all applicable jurisdictions;
  2. provide NABP with the information necessary to verify that all persons affiliated with the site, including those affiliated through contractual or other responsible arrangements, that are engaging in the practice of pharmacy are appropriately licensed or registered and in good standing in all applicable jurisdictions;
  3. maintain and enforce a comprehensive policy and procedure that documents how the pharmacy’s policies and procedures are organized, authorized for implementation, revised, retired, and archived; and
  4. comply with all applicable statutes and regulations governing the practice of pharmacy where licensed or registered, and comply with the more stringent law or regulation as determined by conflicts of law rules. Vet-VIPPS pharmacies must maintain and enforce policies and procedures that address conflicts of law issues that may arise between individual states or between state and federal laws and regulations. Said policies and procedures must ensure compliance with applicable laws, including generic substitution laws and regulations, and must prohibit unauthorized therapeutic substitution from occurring without necessary client or prescriber authorization.

Prescriptions

Qualifying Vet-VIPPS Pharmacies, in accordance with applicable state and federal laws and regulations, must:

  1. maintain and enforce policies and procedures that ensure the integrity, legitimacy, and authenticity of the Prescription Drug Order and seek to prevent Prescription Drug Orders from being submitted, honored, and filled by multiple pharmacies. Maintain and enforce policies and procedures that ensure that prescription medications are not prescribed or dispensed based upon telephonic, electronic, or online medical consultations without there being a pre-existing veterinarian-client-patient relationship (VCPR). As defined by the 21CFR530.3 (i), a VCPR exists when all of the following conditions have been met:
    1. a veterinarian has assumed the responsibility for making medical judgments regarding the health of (an) animal(s) and the need for medical treatment, and the client (the owner of the animal or animals or other caretaker) has agreed to follow the instructions of the veterinarian;
    2. there is sufficient knowledge of the animal(s) by the veterinarian to initiate at least a general or preliminary diagnosis of the medical condition of the animal(s); and
    3. the practicing veterinarian is readily available for follow-up in case of adverse reactions or failure of the regimen of therapy. Such a relationship can exist only when the veterinarian has recently seen and is personally acquainted with the keeping and care of the animal(s) by virtue of examination of the animal(s), and/or by medically appropriate and timely visits to the premises where the animal(s) are kept.

Patient/Client Information

Qualifying Vet-VIPPS Pharmacies, in accordance with applicable state and federal laws and regulations, must:

  1. maintain and enforce policies and procedures ensuring reasonable verification of the identity of the patient/client and prescriber in accordance with applicable state law;
  2. obtain and maintain in a readily accessible format, patient medication profiles and other related data in a manner that facilitates consultation with the prescriber, when applicable, and counseling of the client;
  3. conduct a prospective drug use review (DUR) prior to the dispensing of a medication or device in accordance with applicable state law; and
  4. maintain and enforce policies and procedures to ensure patient/client confidentiality and the protection of patient/client identity and patient-specific information from inappropriate or non-essential access, use, or distribution while such information is being transmitted via the Internet and while the pharmacy possesses such information.

Communication

Qualifying Vet-VIPPS Pharmacies, in accordance with applicable state and federal laws and regulations and Vet-VIPPS program criteria must:

  1. maintain and enforce policies and procedures requiring pharmacists to offer interactive, meaningful consultation to the client;
  2. maintain and enforce policies and procedures establishing a mechanism for client to report and the Vet-VIPPS Pharmacy to take appropriate action regarding suspected adverse drug reactions and errors;
  3. maintain and enforce policies and procedures that provide a mechanism to contact the client and, if necessary, the prescriber, if an undue delay is encountered in delivering the prescribed drug or device. Undue delay is defined as an extension of the normal delivery cycle sufficient to jeopardize or alter the patient treatment plan;
  4. maintain and enforce policies and procedures establishing mechanisms to inform clients about drug recalls; and
  5. maintain and enforce policies and procedures establishing mechanisms to educate clients about the appropriate means to dispose of expired, damaged, and unusable medications.

Storage and Shipment

Qualifying Vet-VIPPS Pharmacies, in accordance with applicable state and federal laws and regulations and Vet-VIPPS program criteria, must:

  1. ship controlled substances to client via a secure means that ensures proper delivery and seeks to prevent diversion; and
  2. ensure that medications and devices are maintained within appropriate temperature, light, and humidity standards, as established by the United States Pharmacopeia, during storage and shipment.

Over-the-Counter Products

Qualifying Vet-VIPPS Pharmacies must:

  1. comply with all applicable federal and state laws regarding the sale of Over-the-Counter Products identified as precursors to the manufacture or compounding of illegal drugs.

Quality Improvement Programs

Qualifying Vet-VIPPS Pharmacies must:

  1. maintain a Quality Assurance/Quality Improvement Program.

Reporting to NABP

Qualifying Vet-VIPPS Pharmacies must:

  1. notify NABP within 30 days of any change of information provided as part of the verification process, including change in pharmacist-in-charge, or involving data displayed on the Vet-VIPPS website. Vet-VIPPS pharmacies shall notify NABP in writing within 10 days of ceasing operations. The written notification shall include the date the pharmacy will be closed, and an affirmation that all Vet-VIPPS Seals and references to the Vet-VIPPS program have been removed from the website and wherever else they are displayed.

 

 Vet-VIPPS Standards

  1. Licensure. The pharmacy, medical practice, medical practitioner, or any such practice or practitioner to which the applicant site links or with which it is affiliated, must be licensed or registered in good standing to practice in all required jurisdictions.
  2. DEA registration. The pharmacy, medical practice, medical practitioner, or any such practice or practitioner to which the applicant site links or with which it is affiliated, if dispensing controlled substances, must be registered with the United States Drug Enforcement Administration (DEA).
  3. Prior discipline. The pharmacy, pharmacist-in-charge, medical practice, medical practitioner, or any such practice or practitioner to which the applicant site links or with which it is affiliated, must not have been subject to significant recent and/or repeated disciplinary sanctions.
  4. Location. The pharmacy, medical practice, medical practitioner, or any such practice or practitioner to which the applicant site links or with which it is affiliated, must be domiciled in the US.
  5. Validity of prescription. A pharmacy shall dispense or offer to dispense prescription drugs only upon receipt of a valid prescription, as defined below, issued by a medical practitioner authorized to prescribe under state law and, as applicable, federal law. A medical practitioner authorized to prescribe must not prescribe, distribute, or offer to prescribe or 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, medical practice, medical practitioner, or any such practice or practitioner to which the applicant site links or with which it is affiliated, must 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). The pharmacy, medical practice, or medical practitioner must not prescribe, dispense, or offer to prescribe or dispense medications that have not been approved by the US Food and Drug Administration (FDA).
  7. Privacy. If the applicant website, or any site to which the applicant site links or with which it is affiliated, transmits information that would be considered Protected Health Information (PHI) under the HIPAA Privacy Rule (45 CFR 164), the information must be transmitted in accordance with HIPAA requirements, including the use of Secure-Socket Layer or equivalent technology for the transmission of PHI, and the pharmacy must display its privacy policy that accords with the requirements of the HIPAA Privacy Rule.
  8. Patient services. The pharmacy, medical practice, medical practitioner, or any such practice or practitioner to which the applicant site links or with which it is affiliated, must provide on the website an accurate US street address of the dispensing pharmacy, medical practice, medical practitioner, or corporate headquarters. The pharmacy, medical practice, medical practitioner, or any such practice or practitioner to which the applicant site links or with which it is affiliated, must provide on the website an accurate, readily accessible, and responsive phone number or secure mechanism via the website, allowing patients to contact or consult with a pharmacist or medical practitioner regarding complaints or concerns or in the event of a possible adverse event involving their medication.
  9. Website transparency. The pharmacy, medical practice, medical practitioner, or any such practice or practitioner to which the applicant site links or with which it is affiliated, must not engage in practices or extend offers on its website that may deceive or defraud patients as to any material detail regarding the practice, its staff, prescription drugs, or financial transactions.
  10. Domain name registration. The domain name registration information of the applicant website, or of any pharmacy, medical practice, or medical practitioner it promotes, must be accurate, and the domain name registrant must have a logical nexus to the dispensing pharmacy, medical practice, or medical practitioner. Absent extenuating circumstances, applicant websites utilizing anonymous domain name registration services will not be eligible for approval.
  11. Affiliated websites. The applicant website, any pharmacy, medical practice, or medical practitioner it promotes, its staff, domain name registrants, and any person or entity that exercises control over, or participates in the applicant business, must not be affiliated with or control any other website that violates these standards.