Table II.5: States Reporting Select Qualifications Required for Pharmacy Inspectors
State Current pharmacist's license Current pharmacy technician's license Law enforcement (e.g., sworn peace officers) Practiced pharmacy for a minimum number of years Prior experience in investigations and/or auditing Prior experience in compounding Completed investigator training program Completed a specialized training program in nonsterile compounding Completed a specialized training program in sterile compounding Other
District of Columbia              
Guam                   f
Minnesota           k
Montana               l
Nebraska               m
New Hampshire            
New Jersey             n
New Mexico              
New York                  
North Carolinao              
North Dakotap              
Oklahoma           q
Rhode Island          
South Carolinar                  
South Dakotas              
West Virginia              

Source: GAO survey of state pharmacy regulatory bodies, survey question 8. | GAO-17-363SP
Notes: GAO surveyed the state pharmacy regulatory bodies in the 50 states, the District of Columbia, Guam, Puerto Rico, and the U.S. Virgin Islands, and all but 4 completed the survey.
aThis state reported that not all of their inspectors conduct inspections of sterile compounding pharmacies, but all inspectors have training in sterile compounding. bThis state reported that other criteria would be requested and screened for in the hiring process, such as relevant experience. cThis state reported that they hire inspectors with a diversity of experience and provide training for inspectors, including specialized sterile compounding training. dThis state reported that their current pharmacy inspector has most of the requirements listed in this table; however, they are not required. eThis state reported the state statutes and rules did not provide for minimum training requirements; however, all sterile compounding inspections are conducted by pharmacists licensed in the state who have prior pharmacy practice and sterile compounding experience, and these inspectors attend regular training on sterile compounding. In addition, the state reported that all other inspectors have prior auditing and/or investigative experience and are provided additional training by the state Department of Health, and a state rule has minimum requirements for inspections of nonresident sterile compounding entities, including requiring approved inspection entities to employ inspectors that have a minimum of 4 years of compounding experience, among other things. fThis state reported that the state does not have pharmacy inspectors; the current pharmacy board members conduct inspections in the state. gThis state reported that the state does not have pharmacy inspectors. hThis state reported that specialized training, such as compounding-related training, is provided as available and as needed for investigators to competently perform job functions. iThis state reported that their inspectors attend training programs/classes to keep current with changes in the pharmacy field. jThese states did not respond to this survey question. kThis state reported that all of their pharmacy inspectors have completed training in how to conduct sterile compounding inspections, in addition to general sterile compounding training. lThis state reported that they also require a pharmacist license having never been suspended or revoked by any board of pharmacy in any state for its inspectors. In addition, the state reported inspectors are required to have 5 years of professional experience in the practice of pharmacy immediately prior to hire, and to be licensed in the state or have the ability to be licensed upon hire. mThis state reported that job announcements for inspectors express preference for experience in investigation and/or sterile compounding although it is not required. nThis state reported that they contracted with the National Association of Boards of Pharmacy to conduct sterile compounding inspections of 180 sterile compounding facilities in the state, and their state pharmacy inspectors accompanied these inspections, resulting in approximately 80 hours of one-on-one, hands-on, sterile compounding inspector training. oThis state reported that law enforcement experience and pharmacy technician experience are preferred qualifications, but not mandatory qualifications for their inspectors. pThis state reported that they rely heavily on the National Association of Boards of Pharmacy for valid inspections of out-of-state pharmacies, and inspectors for in-state pharmacies are focused on pharmacies that fall under their expertise. qThis state reported that they provide extensive inspector training on compounding through a company that provides training and education in sterile compounding, and other educational organizations. rThis state reported that, once hired, pharmacist inspectors complete on-the-job training for investigator, nonsterile and sterile compounding programs. sThis state reported that there are no requirements in state law or rule, but the requirements checked are their pharmacy board's requirements. tThis state reported that they employ pharmacists and pharmacy technicians as inspectors. uThis state reported that the state’s rules do not address any specific requirements for pharmacy inspectors. vThis state reported that the training is completed once the pharmacy inspector is hired. wThis state reported that all field pharmacist investigators have completed 40 hours of online training and a three-day boot camp.