Transferring a Pharmacy Licence

It seems like you always hear horror stories about doctors who lose their license in one state because of terrible malpractice. These doctors seem to be able to move to another state all willy-nilly and start over again. I'm sure I've read all about this in the Reader's Digest!

It is not that way with pharmacy.

You may have heard that there is a shortage of pharmacists. My wife gets some sort of job offer every week by mail or phone. The general population is aging and in need of a wide array of drugs to ease their passage to the next life. Pharmacies are popping up on almost every street corner. At the same time, the number of pharmacists graduating is not increasing much, and many older pharmacists are retiring. Many of the pharmacists that graduate are women, and many of them only want to work part time (like my wife). These factors are resulting in a huge shortage of pharmacists.

We're moving to Arizona for a job change for me. Because of the pharmacy shortage and because she's really good, my wife was able to easily find a great job with great benefits. In contrast, getting her pharmacy licence changed to an Arizona licence has been amazingly difficult. This is a great showcase of government bureaucracy at work. Since there doesn't seem to be any other guide to this process, I thought I'd create a helpful step-by-step guide for any other foolish saps that want to transfer their pharmacy license to Arizona.

How to get Arizona to accept a transfer of an out of state pharmacy licence

Step 1: Send $300 and application form to National Board of Pharmacy.
Step 1a: Wait for 3-4 weeks for the National Board of Pharmacy to review the application form and mail a different application form back.
Step 1b: Receive application form from the National Board for the Arizona State Board

But wait, my wife didn't explain on the 'job history' section of the application what she was doing in the spring 1999. (She was on bed rest for 4 months, pregnant with our 8yo). This requires a significant delay as she had to respond to their request for information.

Step 2: Send $300 and the state application form from the National Board to the Arizona State Board of Pharmacy
Step 2a: Wait for 2 weeks for the Arizona State Board of Pharmacy to review the application form and mail a different application form back.
Step 2b: Receive new application form and 1 inch thick packet of Arizona State Pharmacy Law. Not a study guide, or a practice test. The actual state law. Here's an excerpt.

36-2522. Registration requirements

A. Every person who manufactures, distributes, dispenses or uses for scientific purposes any controlled substance within this state or who proposes to engage in the manufacture, distribution, dispensing of or using for scientific purposes any controlled substance within this state must first:

1. Obtain and possess a current license or permit as a medical practitioner as defined in section 32-1901 or as a pharmacy, pharmacist, manufacturer or wholesaler pursuant to title 32, chapter 18.

2. Be a registrant under the federal controlled substances act (P.L. 91-513; 84 Stat. 1242; 21 U.S.C. sec. 801 et seq.).

B. A person who is registered under this chapter to manufacture, distribute, dispense or use for scientific purposes controlled substances may possess, manufacture, distribute, dispense or use for scientific purposes those substances to the extent authorized by that person's license or permit in conformity with this chapter and title 32, chapter 18.

C. The following persons need not register and may lawfully possess controlled substances under this chapter:

1. An agent or employee of any registered manufacturer, distributor or dispenser of any controlled substance if he is acting in the usual course of his business or employment.

2. A common or contract carrier or warehouseman or that person's employee whose possession of any controlled substance is in the usual course of business or employment.

3. An ultimate user or a person in possession of any controlled substance pursuant to a lawful order of a medical practitioner or in lawful possession of a schedule V substance.

4. An officer or employee of the department of public safety or the board or a peace officer as defined in section 1-215 in the lawful performance of that person's duties.

D. The board may waive by rule the requirement for registration of certain manufacturers, distributors or dispensers if the board finds waiver consistent with the public health and safety or the requirements of the United States drug enforcement administration.

E. The board may inspect the establishment of a registrant or applicant for registration in accordance with the board's regulation.

When laws are written like this, I wonder how the police know if someone has broken a law? The parts of law that are readable by a non-lawyer are so boring that my mind skips over it all. Did you read it all? I didn't. But my wife had to read it and remember it as possible test material. Yuck.

While you're (not) reading section 36-2522, remember that this is just one little piece of all the laws. The entire applicable pharmacy law is an inch thick! Of 8 by 10 paper! The test covers all of the laws and they often ask trick questions! Studying for this is not a trivial matter. Oh, and it costs you $185 per attempt. Oh, and you only get 3 tries before you have to appear before the Arizona State Board to explain why a complete idiot like yourself that can't pass their simple little test should deserve another chance. So, at least there's no pressure.

Step 3: Send a whole bunch of information including marriage license, birth certificate, university graduation information, residency hours, bla bla bla, to the Arizona board. They also want another $300.
Step 3a: Wait for the Arizona board to review the information and, if approved, forward said approval to the National Board. The National Board then sits on it for a while. After sufficient aging, the National Board generates a letter approving the applicant to take the state law test and sends it to you. This takes approximately 3 weeks.

Lucky you! The test is administered at some sort of nationwide testing center called Prometrics. Of course, there are three centers in my state. One is 30 miles away, one is 60 miles away, and the third is 350 miles away. It's nice of them to give us a selection of convenient locations!

We finally received this letter yesterday. EIGHT weeks after beginning this process. My wife was thrilled to finally have the testing letter and to get it all behind her. Then she looked over the the bunch of new rules listed therein. One of the new rules was that the name listed on the letter had to match EXACTLY with your picture ID that you will bring with you to the testing center. Can you see what's coming?

She had used the same name on her application that she used on her licence for the state where we currently live. She thought that would be simpler and cause fewer problems with the licence transfer. Wrong. Unfortunately, she included her maiden name as a middle name on her driver's licence, but not on her pharmacy license application. Just so you notice what just happened, I'll summarize. The name on her testing approval letter DOES NOT exactly match the name on her photo ID. Crap.

No problem, I thought. It's just her maiden name, they'll understand. A quick phone call should clear this right up! If it was so critical, they would have had some sort of BIG BOLD NOTE on the first set of forms we sent to the National or State Boards of Pharmacy.

(Hint for the National and Arizona Boards of Pharmacy: Notice how BIG BOLD NOTES stand out on a page full of text. If there is some information that you need in a certain format, and having the incorrect format can derail a complicated 8 week process that requires 4-5 separate mailings, please have a BIG BOLD NOTE at the beginning of the process explaining this important detail! Or maybe put it on your website that details this complicated process. Or maybe have a website that details this process. That would really help. This process is really confusing. Thanks.)

A call today to Prometrics verified that the names have to match exactly, or the tester will not be allowed in. A call to the National Board was also unhelpful. According to them, they need to issue another approval letter with the corrected name. They wanted us to fax to them the following information: a letter detailing what had happened, her driver's licence, a second form of ID that includes her full maiden name or the initial of her maiden name, and finally a copy of her marriage licence with her maiden name. Figuring this out only took 2 hours on the phone. I'm surprised they didn't want $300.

Processing this information to produce a new letter will take approximately 7 more business days. Then they have to mail it to us. Then she has to schedule a testing time at this Prometrics place.

Step 4: Schedule to take the state law test at Prometrics. They schedule the test for about 7 days after you call to schedule.

Step 5: Take the state law test.
Step 5a: Rinse and Repeat as needed. (But only 3 times, sorry!)

Whew! What a pain. It's almost like they don't want pharmacists to move to Arizona. I don't think we'll be changing states again. How do those malpractice doctors do it? Maybe I'd better write Reader's Digest and find out.