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?

22-B DCMR §1903 requires nonresident pharmacies that dispense, distribute, ship, mail or deliver prescription drugs or medical devices into DC, directly or indirectly, to be registered by the Department of Health and to follow DC pharmacy and drug law (unless that would violate home-state law); no shipments are allowed until a Certificate of Registration issues. Applicants must show a home-state pharmacy license, a pharmacist-in-charge licensed in the home state (who signs an affidavit about DC law), DEA registration if shipping controlled substances, the most recent home-state or federal inspection report, whether they perform sterile compounding, and a DC resident agent; internet-based pharmacies must also hold NABP VIPPS (or equivalent) certification. Nonresident pharmacies must provide a toll-free pharmacist line (6 days/40 hours a week) on each label, keep DC dispensing records for 5 years, and produce records within 3 business days. DC Health's 2025 checklist lists a $900 nonresident pharmacy license fee and says a separate application is needed for each shipping location.

DC's credential is described as both a 'registration' (22-B DCMR §1903) and a 'Non-Resident Pharmacy license' (DC Health checklist). The rule asks whether the pharmacy does sterile compounding but sets no separate nonresident sterile-compounding permit. The in-District pharmacy license statute (D.C. Code §47-2885.03) applies to pharmacies 'within the District'; the nonresident requirement comes from the DCMR rule. Stale-source flag: the controlling text is dated 2024-03-05 (more than 2 years before 2026-09-23); it is the latest version found, but confirm with the board that it is still current.

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.

D.C. Code §3-1201.02(11) defines the practice of pharmacy to include 'the compounding of drugs as authorized by federal and District law.' No DC statute or DCMR provision found (22-B DCMR ch. 19 Pharmacies; 17 DCMR ch. 65 Pharmacists) sets office-use quantities, labeling or other conditions, and none expressly prohibits office use. Because DC defers to federal law and FDA's position is that 503A compounding requires patient-specific prescriptions, DC law does not by itself confirm that a 503A pharmacy may supply office stock. DC Health's Pharmaceutical Control Division and the Board of Pharmacy regulate pharmacies.

Silent. §3-1201.02 was last amended by D.C. Law 26-105 (effective 2026-03-24); the fetched definition still ties compounding to federal and District law. The Board's policy-statement list (https://dchealth.dc.gov/node/158712, checked 2026-09-23) has no compounding or office-use statement. Check with DC Board of Pharmacy before relying on office-use supply.

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?

D.C. Code §48-702 bars manufacturing, distributing or wholesaling any drug in the District without a license or registration from the Mayor (DC Health), and §48-701 defines 'manufacture' to include compounding and 'wholesaler' to include manufacturers and pharmacies that distribute to anyone other than a consumer or patient. DC Health's checklist (revised 1/15/2025) states that an out-of-state or in-state manufacturer, distributor or wholesaler, 'or any other facility' that intends to ship prescription, OTC or controlled drugs to or within DC must first obtain a DC registration, with a $100 nonresident fee, proof of current FDA approval (manufacturers), home-state licensure, a list of products to be shipped, and the most recent state or federal inspection report (with corrective-action proof if deficiencies were cited). A separate application is required for each shipping location, and controlled substances require an additional DC controlled substance registration.

No DC provision names 'outsourcing facility'; the requirement for out-of-state facilities comes from DC Health's application checklist, while the statute speaks of activity 'in the District'. A 503B dispensing patient-specific prescriptions into DC would also need nonresident pharmacy registration (22-B DCMR §1903). 22-B DCMR ch. 4 text was not separately reviewed.

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; District of Columbia 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.

D.C. Code Sec. 48-903.02(a) requires every person who manufactures, distributes or dispenses any controlled substance within DC to obtain annually a registration issued by the Mayor, and renewal applications must be filed at least 60 days before expiration or the registration abates. Subsection (e) requires a separate registration for each principal place of business or professional practice where controlled substances are dispensed. The statute vests issuance in the Mayor; the DC Health program page could not be opened in this session, so the agency office, fee and current cycle should be checked with DC Health. DEA registration requires state/district authority to handle controlled substances, so the DC registration is obtained before the DC DEA registration.

Fee and current renewal cycle could not be confirmed on a DC Health page in this session (the DC Health CSR page URLs tried returned 404); the statute text says 'annually'. Last statutory amendment shown is 1999 (D.C. Law 12-284), but the Code page is current.

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.

D.C. Code 48-853.03c requires a prescriber or delegate to query the DC PDMP before starting a new course of treatment that includes an opioid or benzodiazepine for more than 7 consecutive days, and every 90 days while it continues. Dispensers must query before dispensing an opioid or benzodiazepine for a course expected to last more than 7 days and before refills more than 90 days after the prior fill. Exceptions: hospice or palliative care; inpatient hospital admission or discharge; nursing home/residential care facilities using a sole-source pharmacy; system outages or disasters; and documented emergencies. Failure to comply is grounds for discipline by the relevant health occupations board and civil fines.

Source older than 2 years - possibly stale (section added eff. 3/16/2021; text confirmed on the official D.C. Law Library on 2026-09-23). The PDMP TTAC list cites 'D.C. Law 23-252 (D.C. Act 23-609)'; the Code's history note cites D.C. Law 23-251, § 101. Testosterone (C-III) is not caught.

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.

D.C. Code 47-2885.01(b)(1) exempts from the pharmacy act a duly licensed medical practitioner who personally dispenses or administers drugs as the practitioner deems proper in treating the practitioner's patients. No separate dispensing permit was found in the statute. Controlled substances require a D.C. controlled substance registration and DEA registration.

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.

A health professional licensed in the District may provide telehealth to a person in D.C. consistent with the D.C. standard of care and scope of practice, and must follow all District and federal laws on prescriptions and controlled substances (D.C. Code 3-1201.05, as cited by CCHP). If there was no prior in-person interaction, a physician may use real-time telemedicine to establish the relationship and evaluate the patient (17 DCMR 4618). No D.C. telehealth-specific Schedule III limit was found. IMLC: member.

The Mayor may add in-person exam requirements for specific professions by rule; none found for physicians.

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?

The DC Board of Nursing (DC Health)'s website was checked on 2026-09-23 for a position statement, advisory opinion or FAQ on cosmetic injectables (neuromodulators, fillers) and none was found. RN practice therefore falls under the state's general nurse practice act, which was not reviewed for this entry.

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?

The DC Board of Nursing (DC Health)'s website was checked on 2026-09-23 for guidance on IV hydration clinics (prior exams, standing orders, mobile services) and none was found.

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 rates DC 'Moderate (Common Law)', citing D.C. Code §§3-1201.02(7)(A), 29-502 and 29-503; MedPath Compliance (reviewed 2026-06-20) calls it 'Nuanced'.

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?

No District of Columbia statute, rule or board policy on delegation of cosmetic laser/IPL procedures or a laser-operator credential was located 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?

DC Health's laboratory page says it serves as the agent for federal CLIA certification, which is 'required for all clinical laboratory testing sites.' It asks labs with an out-of-state CLIA certificate that run temporary screenings or health fairs in DC to notify DC Health through a Health Awareness Screening form. The page describes no separate District license.

Confirm with DC Health (DCHealth.CLIA@dc.gov) that no DCMR licensing rule applies.

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 District of Columbia's rule. District of Columbia's lab regulator (CLIA state agency) is DC Health, Health Care Facilities Division, Laboratory Programs (DCHealth.CLIA@dc.gov, 202-727-1740; https://dchealth.dc.gov/page/laboratories). 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. District of Columbia 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?

District of Columbia does not appear on 2026 compilations of state PFAS-in-cosmetics laws, on the list of states banning animal-tested cosmetics, or among the jurisdictions with sunscreen-ingredient bans. Federal MoCRA and FDA rules on cosmetics and OTC sunscreens still apply. Other state laws that touch cosmetics generally, such as state food-drug-cosmetic acts or consumer-protection laws, were not surveyed.

The animal-testing list is Wikipedia's 'as of 2023' compilation (older than 2 years); effective dates were not confirmed.