DSCSA

DSCSA

Section 582(d)(1)(A)(ii) of the FD&C Act states that “a dispenser . . . prior to, or at the time of, each transaction in which the dispenser transfers ownership of a product (but not including dispensing to a patient or returns) shall provide the subsequent owner with transaction history, transaction information, and a transaction statement for the product, except that the requirements of this clause shall not apply to sales by a dispenser to another dispenser to fulfill a specific patient need.” Section 581(19) of the FD&C Act defines “specific patient need” as the transfer of a product from one pharmacy to another to fill a prescription for an identified patient. Section 581(19) further states that this term does not include the transfer of a product from one pharmacy to another for the purpose of increasing or replenishing stock in anticipation of a potential need.

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