What entities may apply for VAWD accreditation?
Wholesale distributors of prescription drugs and devices that reside within the United States are eligible to apply for VAWD accreditation. Some distinctive business models, while eligible for VAWD accreditation, are subject to considerations consistent with their operations.
Prior to applying for VAWD accreditation, outsourcing facilities must meet all of the below conditions.
- Must be registered with FDA as an outsourcing facility
- Must be the recipient of an inspection that occurred subsequent to registration with FDA that indicates compliance with current Good Manufacturing Practices and required provisions of the Federal Act
- Must have no open FDA actions or must be able to substantiate ongoing communication with FDA towards resolution. This includes unresolved 483s, warning letters, or recalls.
- Must not be the subject of serious FDA regulatory actions or any criminal investigation prior to registration
- Must ship in accordance with their home state’s (and states to which they ship product) current license requirements for outsourcing facilities (pharmacy, wholesaler, or both)
Failure to meet these conditions may result in the application being closed or loss of the VAWD accreditation.
Pharmacy Co-located with Wholesale Distributor
Co-located pharmacies and wholesale distributors are subject to additional scrutiny, potentially requiring the submission of additional documentation to demonstrate they are in compliance with the below stated state and federal laws and VAWD criteria. This might lengthen the time it takes to become accredited.
- The pharmacy cannot meet the definition of a public or private hospital pharmacy or other health care entity.
- The pharmacy must comply with state record-keeping and audit trail laws for prescription drugs, including authorized trading partners and transaction documents.
- The wholesale distributor and pharmacy must have physical separation adequate for securing drugs.
- The pharmacy and wholesale distributor transactions must employ separate account numbers to distinguish prescription drug purchases made by the two entities.
- Wholesale distributors cannot sell drugs that were at any time purchased by a pharmacy. Specifically, wholesale distributors that have a license issued in the same name and address as a pharmacy cannot sell drugs purchased under the pharmacy account.
- Pharmacies purchasing drugs as part of a Group Purchasing Organization or certain programs such as the federal 340B Drug Pricing Program must demonstrate they are not limited in the use of drugs purchased under these contracts.
Third Party Logistics Providers (3PLs)
Any 3PL seeking and maintaining VAWD accreditation may distribute only on behalf of FDA-registered manufacturers or VAWD-accredited wholesale distributors.