Beginning January 1, 2026, the Illinois Board of Pharmacy will require "out-of-state" (non-resident) pharmacies licensed or seeking licensure in Illinois to have a pharmacist-in-charge (PIC) who is licensed in Illinois. Generally, Illinois requires pharmacies located outside of Illinois that dispense medications for Illinois residents and mail, ship or deliver prescription medications into Illinois to obtain a non-resident pharmacy license.
The change in requirements for PICs of these non-resident pharmacies is a result of the Illinois Board of Pharmacy's amendments to its Rules and Regulations Promulgated for the Administration of the Illinois Pharmacy Practice Act, which took effect on June 28, 2024. The Illinois Board of Pharmacy amended Section 1330.550 of such regulations to state that "[b]eginning January 1, 2026, pharmacists-in-charge of nonresident pharmacies shall be licensed in Illinois." Ill. Admin. Code tit. 68, § 1330.550(a).
The Illinois Board of Pharmacy has not published an amended Illinois Pharmacy License Application that specifically requests the PIC's Illinois pharmacist license number. Additionally, the Illinois Board of Pharmacy has not clarified if it will require pharmacies to make an interim disclosure of its PIC's Illinois pharmacist license number, or if such disclosure may be made upon the subsequent renewal of the non-resident pharmacy's license, which will not be due until March 31, 2026. See Ill. Admin. Code tit. 68, § 1330.550(c). However, currently, PICs of currently licensed Illinois non-resident pharmacies are encouraged to have their PIC complete the Illinois Pharmacist Application for Licensure in advance of the January 2026 effective date to account for the processing time it may take the Illinois Board of Pharmacy to issue the new pharmacist license. Non-resident PICs can apply for licensure using the Illinois Department of Financial & Professional Regulation Online Services Portal.
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