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State Dispensing Regulations
Physician dispensing is regulated on the state level, with widely varying rules. The American Medical Association’s official policy states that physicians have a “right to dispense drugs and devices when it is in the best interest of the patient and consistent with AMA’s ethical guidelines” (Motion of the Board, February 1988; Reaffirmed, BOD-1, AM 2014). Most states have opted to follow the AMA guidelines and allow physician dispensing within certain guidelines. Many states allow physicians to dispense under their state medical license, others require a permit for controlled substance dispenses, and some require a permit for dispensing any legend drugs.
We have compiled some information on state physician dispensing regulations at the links below. This information is provided for reference only. You should consult an attorney or your state medical or pharmacy board to verify your eligibility to dispense and ensure compliance with state and federal regulations.
AL
MDs and DOs: May dispense medications to their patients in Alabama under their state medical license. No dispensing permit is required for non-controlled legend drugs, but a permit is required for controlled substances. PAs: RNs: May not dispense controls
Permit: Yes, for MDs and DOs. CSR $100
Permit Link: Click here
Rules and Regulations: https://www.albme.gov/licensing/md-do/registrations/dispensing-physicians
AK
Physician dispensing is allowed in Alaska; however, a physician may not represent him or herself as a pharmacist or as having a pharmacy on site, and must comply with applicable professional and ethical standards, as well as prescription counseling. Physicians should notify the Alaska Composite Medical Board of their intent to begin dispensing.
Permit: No
Permit Link: N/A
Rules and Regulations: https://namsdl.org/wp-content/uploads/Prescribing-and-Dispensing-Profile-Alaska.pdf
AZ
MDS, DOs and DPMS cna dispense. Under Arizona Statute 32-1491, a doctor of medicine can dispense legend drugs to his or her patients as long as the practitioner is registered with the board as a dispensing doctor and meets certain other requirements, such as securing medications in a locked cabinet or room. Please contact your PharmaLink representative for the current Arizona dispensing permit application. MDs and DOs can dispense, PAs and RNS can dispense but with delegating MD or DO.
Permit: Yes. MD $200, $150 renewal. DO $240. DPM $0
Permit Link: Click here
Rules and Regulations: https://apps.azsos.gov/public_services/Title_04/4-16.pdf
AR
Physician dispensing is allowed in Arkansas but with a permitting requirement that typically renders it unfeasible. In order to be issued a dispensing permit, a physician must display a need to dispense a specific legend drug to the physician’s patients, such as difficulty for patients to obtain the medication or distance to the nearest pharmacy
Permit: Yes
Permit Link: Click here
Rules and Regulations:
CA
MDs and DOs can dispense. PAs and RNs can dispense under supervision of MD or DO. Physician dispensing is explicitly allowed in California under Pharmacy Law Article 12, Section 4170. Physicians may dispense legend drugs to patients under their California state medical license, as long as they meet specific criteria, such as only dispensing to the physician’s own patients and meeting certain labeling criteria. In California, nurse practitioners may hand the medication to the patient as long as it is properly labeled and was prepackaged by a physician, manufacturer, or pharmacist.
Permit: No
Permit Link: N/A
Rules and Regulations: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC§ionNum=4170 Pharmacy Law Article 12, Section 4170
CO
MDs, DOs and DPMs can dispense. RNs cannot dispense. Physician dispensing in Colorado is explicitly allowed in Colorado Revised Statute Title 12, Article 42.5, Section 118, which states that a practitioner may personally compound and dispense for any patient under the practitioner’s care any drug that the practitioner is authorized to prescribe and that the practitioner deems desirable or necessary in treating a patient. There is no permit or registration required; however, any physician dispensing controlled substances must obtain a DEA registration. Physician Assistants (PAs) may also prescribe and dispense under the protocols and supervision of a licensed physician. Nurse Practitioners (NPs) may prescribe and dispense under certain protocols only prepackaged drugs prepared by a licensed pharmacist or manufacturer
Permit: No
Permit Link: N/A
Rules and Regulations: https://drive.google.com/file/d/1WhGuJ9aoH_3uqDz-RJ-0tUWnoySjZ0Fm/view Colorado Revised Statute Title 12, Article 42.5, Section 118
CT
MDs, DOs, DPMs, PAs and RNs can dispense. Physician dispensing is allowed in Connecticut. Physicians may dispense non-controlled legend drugs under their state medical license with no permit required. Physicians who would like to dispense controlled substances must complete the Connecticut Controlled Substance Registration for Practitioners application and pay a small fee in order to dispense controlled substances
Permit: Yes, $48 CSR
Permit Link: Click here
Rules and Regulations: https://portal.ct.gov/DCP/Drug-Control-Division/Drug-Control/Controlled-Substance-Registration-for-Practitioner-Frequently-Asked-Questions#Question1https://www.cga.ct.gov/current/pub/Chap_378.htm#sec_20-87a
DE
MDs, DOs, PAs and RNs may dispense. Physician dispensing is allowed in Delaware with no dispensing permit required. Physician Assistants (PAs) and Nurse Practitioners (NPs) may also dispense under their respective licenses. Practitioners who wish to dispense controlled substances must apply for a Controlled Substances Registration and maintain an active DEA registration
Permit: No
Permit Link: N/A
Rules and Regulations:
FL
MDs and DOs can dispense. Physicians who wish to dispense medications in Florida must register with the Florida Department of Health as a “dispensing practitioner” and pay a fee (currently $100). Physicians may also submit a form to the Florida Department of Health which allows them to delegate dispensing duties to a registered Physician Assistant (PA).
Permit: Yes, $100
Permit Link: Click here
Rules and Regulations: http://www.leg.state.fl.us/statutes/index.cfm?mode=View%20Statutes&SubMenu=1&App_mode=Display_Statute&Search_String=s.+465.0276&URL=0400-0499/0465/Sections/0465.0276.html
GA
Physicians in Georgia may dispense legend drugs to their patients without a permit, but only after notifying the Georgia Composite Medical Board in writing of their intent to act as a dispensing physician. State law allows physicians to dispense pharmaceuticals (in addition to “samples”) from their office only after notifying the Georgia Composite Medical Board in writing of their intent to act as a dispensing physician. This notification may be made by letter to the Board, or may be noted on the renewal of license form.Once this notification is received by the Board, a copy is kept on file in our office and a copy is forwarded to the Georgia Pharmacy Board. The Pharmacy Board keeps a copy and sends an additional copy to the Georgia Drugs and Narcotics Agency (GDNA), the agency that enforces the pharmacy law. The GDNA notifies the Agent in the appropriate territory of the state which physicians have dispensing authority in their territory.No confirmation letters are sent to the physician by any of the agencies, so it would be in the physician’s best interest to send notification to the Board by certified mail, return receipt requested, and to keep the proof of delivery in your business records.
Permit: No but must submit letter of inent to dispense to GA CMB
Permit Link: N/A
Rules and Regulations: https://medicalboard.georgia.gov/become-dispensing-physician
HI
Physicians in Hawaii may dispense legend drugs to their patients but must obtain a wholesale prescription drug distribution license and pay a small fee.
Permit: Yes, $239-$410
Permit Link: Click here
Rules and Regulations: https://www.capitol.hawaii.gov/session2019/bills/HB1560_.HTM
ID
Physicians may dispense legend drugs in Idaho under Idaho Revised Statutes Title 37, Chapter 27, Article III Section 37-2722, so long as the individual is acting within the jurisdiction, scope and authority of his or her license when issuing the prescription. Prescribers must also apply for and receive a Prescriber Drug Outlet Registration and pay a small fee.
Permit: No
Permit Link: N/A
Rules and Regulations: https://legislature.idaho.gov/statutesrules/idstat/title37/t37ch27/sect37-2722/
IL
Physicians in Illinois may dispense non-controlled legend drugs under their state medical license as long as they comply with state and federal laws. Every person who prescribes and/or stores and dispenses any controlled substances within the state of Illinois must obtain a license issued by the Department of Financial and Professional Regulation in accordance with the Illinois Controlled Substances Act. Practitioners must register each location where controlled substances will be held and pay a nominal $5 fee per registration.
Permit: Yes, CSR $5
Permit Link: Click here
Rules and Regulations: https://www.ilga.gov/legislation/ilcs/fulltext.asp?DocName=022500600K33
IN
MDs, DOs, PAs and APRNs may dispense. Licensed physicians, advanced practice nurses, and physician assistants may dispense legend drugs in Indiana in the course of their professional practice. The legend drugs must be delivered in good faith by a practitioner and the practitioner must follow all state and federal laws, including labeling and reporting requirements (if dispensing controls).
Permit: No
Permit Link: N/A
Rules and Regulations: https://www.in.gov/pla/files/2007PharmacyCompilationV1.pdf
IA
Physicians in Iowa may dispense non-controlled legend drugs within their medical purview, so long as they meet all labeling requirements and follow all state and federal regulations. Physicians dispensing controlled substances must apply for a controlled substance registration permit and pay a fee (currently $90 every two years)
Permit: Yes $90
Permit Link: Click here
Rules and Regulations:
KS
MDs, DOs and PAs can dispense. Physicians and Physician Assistants in Kansas may dispense non-controlled legend drugs to their patients, so long as they meet all labeling requirements and follow all state and federal regulations.
Permit: No
Permit Link: No
Rules and Regulations: K.A.R. 100-21-1 through K.A.R. 100-21-5 http://www.ksbha.org/documents/publications/PracticeHandbook_MD_DO_DC.pdf
KY
Kentucky permits physicians to dispense medications in the normal course of their practice that they are authorized to prescribe. Under Kentucky law, the physician may not delegate the dispensing duties to Physician Assistants, Nurse Practitioners or other staff. No license is required to dispense
Permit: No
Permit Link: N/A
Rules and Regulations: https://apps.legislature.ky.gov/law/kar/201/009/260.pdf
LA
Physicians who wish to dispense medications in Louisiana must register with the state as a dispensing physician and pay the registration fee (currently $75). Dispenses of controlled medications are limited to a 48-hour supply. Before applying for a dispensing permit, physicians should read the Louisiana State Board of Medical Examiner’s dispensing rules here. Advance Practice Registered Nurses (APRNs) are allowed to hand prepackaged medications to the patient (“distribute”).
Permit: Yes, $75
Permit Link: Click here
Rules and Regulations: http://www.lsbme.la.gov/sites/default/files/documents/Rules/Individual%20Rules/Physicians%20Feb%202017.pdf
ME
Physician dispensing is currently permitted in Maine under the physician’s state medical license. As always, all state and federal regulations for storage and labeling of medications must be followed. RN may dispense controls under supervision of physician
Permit: No
Permit Link: N/A
Rules and Regulations: https://www.maine.gov/dhhs/samhs/osa/data/pmp/index.htmhttp://legislature.maine.gov/statutes/32/title32sec2258-B.html
MD
MDs and DOs can dispense medications in Maryland but must first obtain a dispensing permit from the Maryland Board of Physicians and pay a fee (currently $1,050). Maryland also requires that dispensing physicians display their dispensing permit at the location where prescription drugs are being dispensed and follow certain labeling and record-keeping requirements. DPMs have their own dispense permit from Maryland Board of Podiatry
Permit: Yes, $1,050
Permit Link: Click here
Rules and Regulations: https://www.mbp.state.md.us/resource_information/res_pro/resource_Practitioner_regs.aspxhttps://health.maryland.gov/mbpme/Pages/permit.aspx
MA
Physicians in Massachusetts can only dispense a single dose or enough for “immediate” needs, making it impractical for physicians to dispense in the state
Permit: No
Permit Link: N/A
Rules and Regulations: https://www.mass.gov/files/documents/2016/10/wz/policy-15-05.pdf
MI
MDs, DO, DPM, DDs, PAs can dispense in Michigan but must first obtain a drug control license (even if only dispensing non-controlled legend drugs) and pay a small fee (currently $48 to $90 depending on length of time until license expiration). Physicians who wish to dispense controlled substances must also apply for a controlled substance license and pay the fee ( currently $90-$120 depending on length of time until license expiration). Mid-level providers may dispense but are limited to dispensing a 72-hour supply.
Permit: Yes, $90-$120
Permit Link: Click here
Rules and Regulations: http://www.legislature.mi.gov/(S(smkf3cvxmpwfy5miaxztsgfq))/mileg.aspx?page=GetObject&objectname=mcl-333-17745
MN
The state of Minnesota allows a physician who is authorized to prescribe legend drugs in the state the ability to dispense those medications during the normal course of practicing medicine. No dispensing permit is required for non-controlled or controlled medications but the physician must comply with all state and federal laws, including labeling requirements and Prescription Drug Monitoring Program reporting. Physicians dispensing for profit must complete and submit the Dispensing Drugs for Profit form to the Minnesota Board of Medical Practice.
Permit: No, but must complete dispense for profit form
Permit Link: Click here
Rules and Regulations: https://mn.gov/boards/assets/Dispense_Drugs_For_Profitr_Report_Form-2009-10.pdf_tcm21-36590.pdf
MS
Mississippi is a very favorable physician dispensing state, with no separate permit required for dispensing, including dispensing controlled substances. Nurse Practioners (NPs) and Physician Assistants (PAs) may also dispense under their licenses. All practitioners dispensing must still ensure they comply with all state and federal regulations.
Permit: No
Permit Link: N/A
Rules and Regulations: https://www.sos.ms.gov/acproposed/00019152b.pdf
MO
Physicians and Physician Assistants in Missouri may dispense medications to individuals with whom they have established a physician/patient relationship. Physicians who wish to possess and dispense controlled medications must apply for a license from the Missouri Bureau of Narcotics and Dangerous Drugs
Permit: Yes, $30 for controls only
Permit Link: Click here
Rules and Regulations: https://www.sos.mo.gov/cmsimages/adrules/csr/previous/20csr/20csr0712/20c2150-5.pdf
MT
Physicians can dispense to their own patients. They can dispense legend drugs. Cannot dispense controlled substances. Newly adopted law as of 5/12/21. They just need to register as a dispenser with MT Board of Pharmacy
Permit: Yes, register with MT BOP
Permit Link: Click here
Rules and Regulations: https://rules.mt.gov/gateway/Subchapterhome.asp?scn=24%2E174.18
NE
Physicians who wish to dispense in Nebraska must first apply for and receive a pharmacy permit. The permit allows physicians to dispense any medication that the physician is eligible to prescribe as long as they comply with all state and federal laws.
Permit: Yes, $625
Permit Link: Click here
Rules and Regulations: https://dhhs.ne.gov/licensure/Pages/Dispensing-Practitioner-Application-Processing-and-Inspection-Information.aspx
NV
Physicians and other practitioners may dispense medications to their patients as long as they comply with all state and federal laws and complete the Application for Authority to Dispense Drugs and receive a dispensing permit. This permit is required for all legend drugs (controlled and non-controlled). Advanced Practice Registered Nurses (APRNs) and Physician Assistants (PAs) may also dispense and have a separate application to complete. The current fee for the physician dispensing permit is $300.
Permit: Yes, $300 for physicians and APRN (separate applications)
Permit Link: Click here
Rules and Regulations: NAC 639.926
NH
Physicians may dispense medications to their patients under their state medical license with no dispensing permit required. Controlled substance dispenses are limited to 48 hours supply for Schedule II medications and 7-days supply for Schedule III through V medications.
Permit: No
Permit Link: N/A
Rules and Regulations: https://www.oplc.nh.gov/sites/g/files/ehbemt441/files/inline-documents/sonh/nh-phcy-law-rule-book-10-29-19.pdf
NJ
Physician dispensing in New Jersey is limited to a 7-day supply, which often makes it impractical for practitioners to dispense. There are additional restrictions and permitting requirements for controlled substance dispensing.
Permit: No, but register with NJ Drug Control Unit
Permit Link: N/A
Rules and Regulations: N.J.A.C. 13:45H-11.2
NM
Physicians may dispense non-controlled legend (prescription) drugs. Physicians may also dispense controlled medications once they have applied for and received a facility controlled substances registration. The fee for this registration is currently $75 per year.
Permit: Yes, $75
Permit Link: Click here
Rules and Regulations: http://www.rld.state.nm.us/uploads/filelinks/a5bdc4c0017d4bf294dd2cbfea6f294e/practitionermanual.pdf
NY
Physician dispensing is limited to no more than a 72-hour supply except for certain specific exceptions.
Permit: No
Permit Link: N/A
Rules and Regulations: http://www.op.nysed.gov/prof/pharm/article137.htm
NC
MDs, DOs, PAs and NPs can dispense medications in North Carolina after applying for and receiving a state Dispensing Physician Registration. Physician Assistants (PAs) and Nurse Practitioners (NPs) may also dispense prescriptions they have written but must also apply for a dispensing permit.
Permit: Yes
Permit Link: Click here
Rules and Regulations: http://www.ncbop.org/lawandrules.htm
ND
Physician dispensing regulations in North Dakota are among the most favorable in the country, with no special permitting requirements. The North Dakota Board of Pharmacy has provided a helpful guide called Administrative Guidelines for Practitioner Dispensing in North Dakota which can be found at the link. Nurse Practitioners (NPs) and Physician Assistants (PAs) may also dispense medications in North Dakota upon approval from prescriber
Permit: No
Permit Link: N/A
Rules and Regulations: https://www.nodakpharmacy.com/pdfs/adminguidelines.pdf
OH
Physician dispensing is allowed in Ohio but there are certain restrictions. Sole practitioners may be able to dispense without a permit, but most practitioners will need to apply for and receive a Terminal Distributor of Dangerous Drugs (TDDD) license (in Ohio, “dangerous drugs” refers to all medications that require a prescription). Physicians may also dispense controlled substances to their patients but there are significant restrictions on the quantity that may be dispensed in a given time frame that often make it impractical to dispense controlled substances. Additionally, dispensers of controlled substances must apply for and receive a TDDD Controlled Substances license.
Permit: Yes
Permit Link: Click here
Rules and Regulations: https://www.pharmacy.ohio.gov/Documents/Licensing/TDDD/General/Terminal%20Distributor%20Licensing%20of%20Prescriber%20Practices.pdf
OK
Physicians in Oklahoma are eligible to dispense medications in the normal course of practicing medicine once they have registered with the state medical board as a dispensing physician (no charge to register).For MDs: When renew their license online indicate that want to dispense, click ‘Yes’. PAs: cannot dispense DOs: need dispensing permit, if they are doing renewal they can add it $50 for each location and APRN and RNs: cannot dispense title 59 sec 3531
Permit: Yes, $50 for DO part of license renewal or can do it online
Permit Link: Click here
Rules and Regulations: http://www.oar.state.ok.us/oar/codedoc02.nsf/All/003B006DE8EDB7298625803C004D4A6A?OpenDocument
OR
Physicians (MDs and DOs) in Oregon can dispense medications to their patients in the ordinary course of practice once they are registered as a dispensing physician. Registering as a dispensing physician requires a simple application with the Oregon Medical Board and is designated on the physician’s state medical license.
Permit: Yes
Permit Link: Click here
Rules and Regulations: ORS 677.089
PA
Physicians can dispense in Pennsylvania under their state medical license to patients under their care, with certain restrictions. In particular, physicians may dispense no more than a 30 day supply of medications (7 days for schedule II and schedule III medications) and must follow all state and federal regulations, including drug storage and labeling requirements.
Permit: No
Permit Link: N/A
Rules and Regulations: https://www.health.pa.gov/topics/Documents/Laws%20and%20Regulations/Code_28.pdf
RI
Physicians in Rhode Island who are authorized to prescribe medications in the state have the ability to dispense those medications to patients under their care during the normal course of practicing medicine. No additional permit or license is required although physicians wishing to dispense controlled medications must register with the state.
Permit: Yes, CSR $200
Permit Link: Click here
Rules and Regulations: http://webserver.rilin.state.ri.us/Statutes/Title21/21-28/index.htm
SC
Physicians can dispense medications in South Carolina to patients under their care. A dispensing permit is required for “non-owned” sites, meaning sites not directly and wholly owned by the dispensing practitioner. Physicians who wish to dispense controlled medications must receive a state-issued controlled substance license. Nurse Practitioners may also dispense with certain restrictions.
Permit: TBD
Permit Link:
Rules and Regulations: §40-43-60(I) http://2hsvz0l74ah31vgcm16peuy12tz.wpengine.netdna-cdn.com/wp-content/uploads/2013/05/herbkersman-b-os-9532-05-21-13-nurse-practitioner-dispense-prescription-drugs.pdf S .C. Code Ann. Section 44-53-290
SD
Physicians in South Dakota may dispense medications to patients under their care but must first complete a controlled substances registration form and pay a small fee (currently $150). Nurse practioners (NPs) and Physician Assistants (PAs) may also dispense as long as it is expressly allowed by their supervising physician.
Permit: Yes, $150
Permit Link: Click here
Rules and Regulations: https://doh.sd.gov/providers/licensure/controlled-substance.aspx
TN
Physicians in Tennessee may dispense medications to patients under their care with no additional permit required, so long as they comply with all state and federal regulations, including drug storage and labeling requirements.
Permit: No
Permit Link: N/A
Rules and Regulations: https://www.tn.gov/content/dam/tn/health/documents/g3010259.pdf
TX
Physician dispensing is not allowed in Texas aside from a handful of exceptions, such as rural clinics.
Permit: N/A
Permit Link: N/A
Rules and Regulations:
UT
Utah does not allow physician dispensing aside from rare exceptions.
Permit: N/A
Permit Link: N/A
Rules and Regulations:
VT
Physicians can dispense in Vermont to patients under their care as long as they comply with all state and federal regulations, including drug storage and labeling requirements. No separate license is required for physician in-office dispensing. Nurse Practitioners (NPs) and Physician Assistants (PAs) may also dispense as long as this responsibility has been delegated by the supervising physician.
Permit: No
Permit Link: N/A
Rules and Regulations: https://legislature.vermont.gov/statutes/section/18/084/04212
VA
Physicians can dispense medications in-office in Virginia but must first apply for and receive a dispensing license, regardless of whether the physicians is dispensing controlled or non-controlled prescription medications. The regulation allows for a pharmacy technician, nurse practitioner, or physician assistant to assist the licensed physician in preparing the drug for dispensing, but the physician must be on site and is responsible for offering to counsel the patient and inspecting the medication, among other requirements. Each dispensing physician must have his or her own license, and the facility where dispensing occurs must also be licensed and may be subject to periodic inspection.
Permit: Yes, $0-$315
Permit Link: Click here
Rules and Regulations: https://www.dhp.virginia.gov/pharmacy/pharmacy_faq.htmhttps://vacode.org/54.1-3304.1/https://www.dhp.virginia.gov/pharmacy/pharmacy_forms.htm
WA
Physician dispensing regulations in Washington state are very favorable and allow physicians to dispense medications in-office to patients under their care with no dispensing permit required. MDs, DOs, DPMs, PAs NPs may dispense in Washington state.
Permit: No
Permit Link: N/A
Rules and Regulations: https://www.doh.wa.gov/LicensesPermitsandCertificates/ProfessionsNewReneworUpdate/PharmacyCommission/WhoCanPrescribeandAdministerPrescriptions
WV
Physicians in West Virginia can dispense medications to patients. For controls a Controlled Substance Dispensing Practioner Registration is required ($30). Medications may only be dispensed to patients under the physician’s care and must be dispensed as part of an office visit. Physicians must also post a sign in a conspicuous place no smaller than 8.5” x 11” including the following language: “Every patient has the right to receive a written prescription as an alternative to having legend drugs dispensed by your physician.”
Permit: Yes, CSR $30
Permit Link: Click here
Rules and Regulations: https://wvbom.wv.gov/download_resource.asp?id=391
WI
Wisconsin is a very favorable state for in-office physician dispensing, requiring no special permit, license or fee for physicians to dispense medications to patients under their care. This applies to both controlled and non-controlled legend drugs. For more information, please review the standards for dispensing and prescribing drugs page
Permit: No
Permit Link: N/A
Rules and Regulations: https://docs.legis.wisconsin.gov/code/admin_code/med/17
WY
Wyoming does not allow physician dispensing outside of rare exceptions.
Permit: No
Permit Link: N/A
Rules and Regulations:
DC
Physicians may dispense in-office in Washington D.C. but must apply for and receive a controlled substances permit if dispensing controlled medications. The current fee for a D.C. controlled substances registration is $130.
Permit: Yes, a CSR $130
Permit Link: Click here
Rules and Regulations:
PR
TBD
Permit:
Permit Link:
Disclaimer
* All research conducted 11/2023. DNA Corp has compiled the information below for reference only. State dispensing regulations change frequently and we recommend consulting an attorney or your state medical or pharmacy board with specific questions or to verify your eligibility to dispense. Mid-level dispensing (PA dispensing and NP dispensing) varies from state to state, even in states where physicians may dispense.