Pharmacy Law Lowdown: Final DSCSA Implementation Updates

In episode 6 of the Pharmacy Law Lowdown, hosts Dae Lee, PharmD, Esq, CPBS, and Lucas Morgan, Esq, shareholders at Buchanan Ingersoll & Rooney, explore the final implementation guidelines for pharmacies to be compliant with the Drug Supply Chain Security Act (DSCSA). “Any sense of cost savings that you believe you're going to recognize from deviating from this is potentially going to be lost through a recoupment or some other type of illegal action,” said Morgan. “I think at the end of the day, the big takeaway here is [to] understand your obligations under both the law and your contracts with payers, and adopt policies and procedures that reflect those requirements.” The DSCSA aims to safeguard the pharmaceutical supply chain by requiring an electronic, interoperable system for tracing prescription drugs. While the law has been in development for over a decade, the final compliance deadline for all pharmacies—including small dispensers—is set for November 27, 2026. To comply, pharmacies must ensure every drug purchase is accompanied by “T3” documentation, which includes the transaction's history, information, and legal statement. Experts warn that even before the federal deadline, many pharmacy benefit managers (PBMs) already demand these records during audits to justify reimbursements. The best defense for a pharmacy is to adopt rigorous purchasing standards by only using accredited wholesalers or manufacturer-authorized distributors. By standardizing these procedures now, pharmacies can avoid the heavy financial penalties or network terminations that often follow discrepancies.