FDA and state rules, for what you actually buy.

Must a pharmacy located in another state hold a license/registration from this state to ship prescriptions (including patient-specific 503A compounded preparations) to patients or practitioners here?

Under Va. Code §54.1-3434.1, any pharmacy outside Virginia that ships, mails or delivers Schedule II–VI drugs or devices into Virginia by prescription must register as a nonresident pharmacy. Schedule VI covers all other prescription drugs. It must designate a pharmacist in charge licensed in Virginia, keep an unrestricted home-state license, and file a current home-state inspection report showing USP-NF compliance for sterile and non-sterile compounding. That report must be no more than 6 months old for a new registration and 2 years old for a renewal. Board Guidance Document 110-38 accepts NABP or Gates Healthcare Associates inspections instead. A pharmacy doing sterile compounding must file an 'operational' inspection report, not just an 'opening' one. Other duties: NABP VIPPS (or Board-approved equivalent) certification if more than 50% of prescriptions come from internet solicitation, a toll-free pharmacist line at least 6 days and 40 hours a week, PMP reporting, and a continuous quality improvement program. A nonresident pharmacy that does sterile compounding must also notify the Board that it intends to ship sterile compounded products into Virginia (§54.1-3410.2(K)).

The Code page showed the statute as current on 9/23/2026 (last amended 2016, c. 221). The LIS 2026 updates index did not list §54.1-3434.1 or §54.1-3410.2. The Board's guidance page lists GD 110-38 as effective June 19, 2025. The Virginia-licensed pharmacist-in-charge requirement does not apply to a registered nonresident pharmacy that acts only as a pharmacy benefits administrator. Under §54.1-3434.1(E), a nonresident pharmacy may deliver dispensed controlled substances only to the patient or the patient's agent, or to a Virginia pharmacy.

May a 503A (traditional) pharmacy dispense or distribute compounded preparations to a practitioner for office use (administration in the office, not patient-specific)? The federal position is that 503A requires patient-specific prescriptions; this is what the state pharmacy act and board rules allow.

Va. Code §54.1-3410.2(A)–(C) limits pharmacist compounding to dispensing on valid prescriptions for specific patients, or in anticipation of such prescriptions based on regular patterns. It bars distributing compounded products for resale or further distribution. The one office-use exception: a pharmacist 'may provide a reasonable amount of compounded products to practitioners of medicine, osteopathy, podiatry, or dentistry to administer to their patients, either personally or under their direct and immediate supervision, if there is a critical need to treat an emergency condition, or as allowed by federal law or regulations.' Each unit must be labeled 'For Administering in Prescriber Practice Location Only', with the name and strength, control number, beyond-use date, pharmacy name and address, and quantity. FDA treats 503A compounding as patient-specific, so routine (non-emergency) office stock under the 'federal law' route generally means a 503B outsourcing facility. The statute does not separately address nonresident pharmacies shipping office stock; registered nonresident pharmacies must follow Virginia's drug laws.

Section last amended by 2025 Acts cc. 48 and 71, per the Code's history line. The companion-animal and veterinary office-use language appears to be the recent change; the chapter text was not retrieved. The LIS 2026 updates index shows no 2026 change to §54.1-3410.2. §54.1-3410.2(H)(2) also bars regularly compounding, or compounding inordinate amounts of, essentially copies of commercially available drugs, with limited exceptions (e.g., shortage, a prescriber-ordered change for an individual patient). No 2025–2026 Virginia Board guidance specific to GLP-1 or peptide compounding was found on the Board's news or guidance pages.

Does the state require an FDA-registered 503B outsourcing facility located outside the state to hold a state license/registration (as an outsourcing facility, nonresident manufacturer, wholesaler or pharmacy) before shipping into the state?

Va. Code §54.1-3434.5 requires any outsourcing facility outside Virginia that ships, mails or delivers Schedule II–VI drugs or devices into Virginia to register as a nonresident outsourcing facility. The application must be signed by a Virginia-licensed pharmacist who is in full and actual charge of the facility and responsible for its compliance. The facility must be registered with FDA under 21 U.S.C. §353b and must file an FDA inspection report no more than 1 year old for a new registration and 2 years old for a renewal. If FDA has not inspected within that window, Guidance Document 110-38 accepts cGMP inspections by the California or Florida Board of Pharmacy or Bestech GMP. Registration renews annually. To fill patient-specific prescriptions, a nonresident outsourcing facility must also register as a nonresident pharmacy (§54.1-3434.5(D)).

The briefing lead cited §54.1-3434.05; that section is the in-state outsourcing facility permit. The nonresident registration is §54.1-3434.5, enacted 2015, c. 300. Outsourcing facilities must compound under federal law and cGMP and are exempt from the pharmacy compounding section §54.1-3410.2. The LIS 2026 updates index shows no 2026 change to either section.

Has the state signed FDA's standard Memorandum of Understanding Addressing Certain Distributions of Compounded Human Drug Products (October 2020)? If not, FD&C Act §503A limits its 503A pharmacies' out-of-state distribution to 5% of total prescription orders (currently not enforced by FDA pending rulemaking).

Signing the standard MOU means the state board agrees to investigate complaints about compounded drugs its 503A pharmacies ship out of state and to identify and report to FDA pharmacies that distribute "inordinate amounts" interstate (more than 50% of their compounded prescriptions); in exchange, the statutory 5% out-of-state cap in FD&C Act §503A(b)(3)(B) does not apply to that state's pharmacies. FDA lists only Colorado, Kentucky and New Hampshire as signatories; Virginia is not among them. For a non-signing state, FD&C Act §503A(b)(3)(B)(ii) caps a 503A pharmacy's out-of-state distribution of compounded drugs at 5% of its total prescription orders. FDA now considers the October 2020 standard MOU suspended (it does not expect signatory states to carry out MOU activities and will not sign new ones) and is not enforcing the 5% limit until a final rule and an updated MOU are published; FDA's rulemaking (RIN 0910-AI71) listed a proposed rule for 11/2026 in the Fall 2025 Unified Agenda.

The FDA list of signed MOUs (current as of 2023-01-23) is older than 2 years, but FDA stopped entering new agreements under the 2020 MOU in October 2022, so no state can have signed since. The FDA "Compounding Information for States" page (current as of 2026-08-28) still describes the MOU as awaiting rulemaking. Pending: FDA proposed rule on 503A distribution (RIN 0910-AI71, NPRM projected 11/2026); H.R. 5316 (introduced 2025-09-11, referred to House Energy & Commerce) would remove the MOU provision from §503A.

Besides DEA registration, does the state require practitioners to hold a separate state controlled substance registration, license or permit to prescribe, administer or dispense controlled substances (e.g. testosterone, Schedule III)? "Conditional" means a state registration is needed only in some settings, such as keeping controlled-substance stock in the office.

Va. Code 54.1-3422(A) requires an annual Board of Pharmacy controlled substances registration (CSR) for anyone who dispenses Schedule I-V substances, but exempts licensed practitioners of medicine, osteopathy, nursing and PAs; a separate registration is required at each principal place of business (54.1-3422(D)). Under 54.1-3304.1, it is unlawful for a practitioner to dispense controlled substances unless licensed by the Board of Pharmacy to sell controlled substances, and the facility must also hold a Board permit (fee-exempt when only one practitioner at the facility holds the license); Virginia's Drug Control Act also includes Schedule VI prescription drugs. Under 54.1-3423(D) and 18VAC110-20-690, outpatient clinics and similar entities may obtain a CSR to keep a stock of Schedule II-VI drugs (after inspection), and the Board may require one where drugs are used as common stock by multiple practitioners and there are red flags such as large purchases, diversion or recordkeeping failures.

Prescribing and in-office administering by an individual MD/DO/NP/PA need no Virginia CSR; dispensing take-home CS needs the practitioner 'license to sell' plus facility permit. 54.1-3304.1 was amended by 2026 Acts cc. 929 and 941 (per the Code history line). Fees and renewal for the practitioner dispensing license were not reviewed.

Must a prescriber query the state Prescription Drug Monitoring Program before prescribing, and does the mandate cover Schedule III drugs such as testosterone? "Yes" means a mandate that reaches Schedule III; "conditional" means a mandate limited to certain drugs (e.g. opioids or benzodiazepines) or situations; "no" means no prescriber query mandate.

Va. Code Sec. 54.1-2522.1(B) (version in effect until July 1, 2027) requires a registered prescriber or delegate, when initiating a new course of treatment that includes opioids anticipated to last more than seven consecutive days, to request PMP information on other covered substances and prior opioid overdoses; prescribers of opioid-addiction therapy must also check before or with the treatment agreement. Exemptions in subsection C: hospice or palliative care, inpatient admission or discharge, nursing homes or assisted living facilities using a sole-source pharmacy, sickle cell pain, and PMP outages or emergencies/disasters. All prescribers of covered substances must be registered with the PMP, which the Department of Health Professions runs. Board of Medicine opioid rules (18VAC85-21) add PMP checks for opioid prescribing.

The official code shows two versions: the current one (effective until July 1, 2027) and a version effective July 1, 2027 that requires a PMP request when initiating treatment with a benzodiazepine or an opiate anticipated to last more than 90 consecutive days, with exemptions for low-abuse-potential drugs listed by the Secretary and for dialysis, cancer or sickle cell pain. Neither version covers testosterone. History includes 2023 cc. 740, 773; 2024 c. 635; 2025 cc. 168, 487.

May physicians dispense prescription drugs (not just administer them) directly to patients from their practice? "Yes" means allowed under standard rules (labeling, records, and at most a simple notice to the board); "conditional" means a separate dispensing registration, permit or license, or quantity, day-supply or drug-category limits; "no" means prohibited except narrow exceptions.

Va. Code 54.1-3304.1 makes it unlawful for a practitioner of the healing arts to dispense controlled substances unless licensed by the Board of Pharmacy to sell controlled substances; facilities where practitioners dispense must hold a Board permit (single-practitioner facilities are exempt from the permit fee). Because Virginia's Drug Control Act treats prescription drugs as Schedule VI controlled substances, this covers ordinary prescription drugs too. A vendor summary notes that each dispensing physician needs an individual license and the facility may be inspected.

Virginia's Drug Control Act includes Schedule VI prescription drugs, so the license covers ordinary prescription drugs. 54.1-3304.1 was amended by 2026 Acts cc. 929 and 941 (per the Code history line); fees and renewal for the practitioner license were not reviewed.

For a patient located in the state: must the prescriber hold this state's license (or a telehealth registration or special license), is an in-person exam required before prescribing (generally or for controlled substances), are there state limits on prescribing Schedule III drugs such as testosterone by telehealth, and is the state an Interstate Medical Licensure Compact member? "Yes" means a state license and the in-person standard of care apply (opioid-only or Schedule II-only limits are described but do not change the answer); "conditional" means extra state conditions such as a telehealth registration route, an in-person exam requirement, controlled-substance limits reaching Schedule III, or registration of telehealth businesses. Federal DEA rules apply on top.

(1) Prescribing to patients in Virginia requires a Virginia license; narrow exemptions cover consultation with Virginia practitioners and continuity-of-care telemedicine by out-of-state physicians for current patients they examined in person within the previous 12 months (Va. Code 54.1-2901(A)(15), (A)(35)). (2) There is no blanket in-person exam requirement: a bona fide relationship for prescribing Schedule II-VI drugs may be established by real-time audio-video or store-and-forward exam if listed conditions are met, including Virginia licensure, a standard of care that does not require an in-person exam and, if the patient is in a health plan, the prescriber being credentialed by that plan. (3) For Schedule II-V drugs (including C-III testosterone) prescribed via telemedicine, the prescriber must comply with federal telemedicine rules and must either maintain a practice at a physical location in Virginia or be able to refer the patient to a Virginia practitioner for an in-person exam when the standard of care requires one. (4) IMLC: not a member.

Classified conditional because Va. Code 54.1-3303 attaches telehealth-specific conditions (Virginia practice location or in-person referral capability; health-plan credentialing when establishing the relationship by telemedicine) to Schedule II-V prescribing, which reaches Schedule III. Board Guidance Doc. 85-12 (Aug. 19, 2021) was read via CCHP, not directly; it says audio-only follow-up for existing patients does not itself require Virginia licensure. Behavioral-health continuity exemption: 54.1-2901(A)(33).

Who may administer botulinum toxin and dermal fillers (physicians, PAs, NPs, RNs, LPNs, estheticians, dentists), under what supervision (on-site vs available), and must a physician/NP/PA perform a prior good-faith exam?

Va. Code §54.1-2901(A)(4) exempts from the unlicensed-practice prohibition any RN, APRN or other properly trained technical personnel rendering care within their usual professional activities, including intravenous infusions and injections, when performed under the orders of a physician, APRN or PA. Subsection (A)(6) separately lets practitioners delegate nondiscretionary tasks to supervised personnel. Board of Medicine rule 18VAC85-20-29 bars delegating patient care to subordinates who are not properly trained and supervised. No Board of Medicine or Nursing rule specific to neuromodulators or fillers was located.

Board of Medicine and Nursing guidance-document lists load dynamically and were not reviewed; they may contain cosmetic-injection guidance.

What does the state require for elective IV hydration/vitamin (incl. NAD+) therapy: who may start IVs, is a patient-specific order or good-faith exam required before a patient's first IV, are standing orders allowed, and are there rules for mobile IV services?

Va. Code §54.1-2901(A)(4) permits RNs, APRNs and properly trained technical personnel to give intravenous infusions and injections within their usual professional activities when performed under the orders of a physician, APRN or PA. No Virginia board statement on elective IV hydration, prior exams, standing orders or mobile IV services was located.

Check with the Virginia Board of Nursing for any IV-hydration guidance document.

Does the state enforce the corporate practice of medicine doctrine (non-physicians may not own medical practices or employ physicians), and how does that affect med spa ownership?

Permit Health's 2025 guide lists Virginia among non-CPOM states, citing Va. Code §§54.1-2902 and 54.1-111, Attorney General opinions (1955, 1992) and Board of Medicine Guidance Document 85-21. MedPath Compliance (reviewed 2026-06-20) also lists Virginia as 'No' and reports HB 1458 (2026), a study bill on corporate practice.

Who may perform laser/IPL/RF aesthetic procedures (laser hair removal, resurfacing): physicians only, delegated to RNs/PAs, or licensed electrologists/estheticians/laser technicians with state certification?

Board of Medicine rule 18VAC85-20-91 (effective 2019-08-07) requires a physician who performs or supervises laser hair removal to be trained in skin physiology, skin typing and patient selection, laser safety, device operation, complications, and at least 10 proctored cases. A physician may delegate laser hair removal to a properly trained person under direction and supervision, meaning the physician is readily available during treatment but need not be physically present; delegates other than PAs and NPs must complete the same training, all must keep up ongoing training, and the physician must see any patient with complications before treatment continues. Other cosmetic lasers fall under general delegation rules.

Rule adopted 2019 (over two years old) but shown as current on LIS on 2026-09-23.

Does the state license clinical laboratories itself, beyond federal CLIA certification, including out-of-state labs that test specimens from the state?

Most states rely on federal CLIA certification alone. The states confirmed in this research as issuing their own lab licenses are California, New York, Pennsylvania, Maryland and Rhode Island (which also reach out-of-state labs testing specimens from their residents), plus Nevada, Washington, Massachusetts, New Jersey and New Hampshire (labs located in the state). Virginia was not among them, but this research did not confirm its statutes. Virginia's CLIA state agency is Virginia Dept. of Health, Office of Licensure and Certification (CLIAlab@vdh.virginia.gov, 804-367-2107); it can confirm whether any state license or permit applies, including to out-of-state labs.

Absence of a state license was not verified against the state's statutes or rules.

May consumers order their own lab tests without a practitioner order (direct access testing)? A practitioner-ordered panel is always fine; this matters for take-home and consumer test kits.

ADLM (formerly AACC) reported in 2019 that 37 states and DC let consumers order some or all tests directly, but it did not publish the state list, and this research did not confirm Virginia's rule. Virginia's lab regulator (CLIA state agency) is Virginia Dept. of Health, Office of Licensure and Certification (CLIAlab@vdh.virginia.gov, 804-367-2107). The question matters for take-home and consumer test kits, not for panels a clinician orders.

The ADLM figure dates from 2019 (older than 2 years).

Has the state enacted a law or rule specifically about stem cell, exosome or regenerative-medicine therapies (notice/disclosure duties, permission for certain non-FDA-approved uses, or Right to Try extensions covering them)?

Compilations of state stem-cell laws from 2024 to 2026 list about a dozen states with specific laws (California, Florida, Georgia, Mississippi, Nevada, North Carolina, Tennessee, Texas, Utah, Vermont, Washington and Wyoming), plus Montana's general experimental-treatment law and Kansas's state stem cell center. Virginia is not among them. Without a state-specific law, regenerative products are governed by federal FDA rules plus the state's general medical practice, advertising and consumer-protection laws, enforced by its medical board. Federal FDA rules still apply regardless of state law: stem cell, birth-tissue and exosome products are regulated by FDA, and a state law cannot make an unapproved biologic FDA-approved.

The finding of no law rests on multi-state compilations (a commercial one from Aug 2026 and a peer-reviewed one from Feb 2024, which is older than 2 years) and targeted searches, not a statute-by-statute review, and neither compilation is exhaustive. General Right to Try laws for terminal patients, where they exist, were not reviewed here.

Does the state have cosmetic or sunscreen requirements beyond federal MoCRA, such as ingredient bans (PFAS, formaldehyde, phthalates), ingredient reporting, sunscreen-ingredient bans, or bans on selling animal-tested cosmetics?

A 2023 compilation lists Virginia among the ten states with cosmetic animal-testing sales bans. Virginia does not appear on 2026 lists of states with PFAS-in-cosmetics laws.

The animal-testing list is Wikipedia's 'as of 2023' compilation (older than 2 years); effective dates were not confirmed. Federal MoCRA and FDA cosmetic and OTC sunscreen rules apply in every state.