3.2 Pharmacist Licensure, Reciprocity, Inactive Status & CE

3.2 Pharmacist Licensure, Reciprocity, Inactive Status & Continuing Education

Quick Answer: In Tennessee, initial pharmacist licensure requires graduation from a Board-recognized (ACPE-accredited) school, completion of 1,700 pharmacy internship hours under Rule 1140-01-.04, and passing results on both the NAPLEX and the Tennessee MPJE (NABP reports both as Pass/Fail — no scaled score is issued). Licenses renew on a biennial (2-year) cycle expiring on the last day of the licensee's birth month. Licensees must complete 30 contact hours of continuing education (CE) every two years under Rule 1140-05, with a strict mandate that at least 15 contact hours must be live/interactive. Reinstatement of an inactive license between 1 and 5 years requires completing 30 CE hours (≥15 live), passing the Tennessee MPJE, and paying fees.

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1. Initial Licensure by Examination

Under T.C.A. § 63-10-310 (recodified from the former § 63-10-306 by Public Chapter 457, effective July 1, 2023) and Tenn. Comp. R. & Regs. 1140-01-.03 and 1140-01-.04, an applicant seeking initial licensure as a pharmacist in Tennessee must satisfy comprehensive educational, internship, and examination standards.

Core Licensure Requirements

1. Age and Moral Character: Must be at least 21 years of age, of good moral character, and submit to a state and federal fingerprint-based criminal history background check.
2. Professional Degree: Must have graduated with a Doctor of Pharmacy (Pharm.D.) or Bachelor of Science in Pharmacy from a school or college of pharmacy accredited by the Accreditation Council for Pharmacy Education (ACPE).
3. Internship Hours: Under Rule 1140-01-.04(1), the applicant must show on Board affidavit forms a minimum of 1,700 hours of pharmacy internship (practical pharmacy experience) obtained under the instruction of a pharmacist in good standing. The hours must be acquired after enrollment in a recognized college or school of pharmacy, and the rule requires that these hours be acquired in pharmacy programs or demonstration projects structured by the college or school — so the accredited experiential curriculum (Introductory and Advanced Pharmacy Practice Experiences, IPPE/APPE) is the normal route. Internship may be acquired in another state if the preceptor's qualifications are certified by that state's authorities.
4. Examination Standards:
   • NAPLEX: Must pass. NABP reports the result as Pass or Fail only — "you will not receive a scaled score." The historic "scaled 75" figure is a legacy passing standard that is no longer reported to candidates.
   • Tennessee MPJE: Must pass, again reported as Pass or Fail only.
   • Waiting Periods for Retakes: If an applicant fails either examination, NABP re-examination waiting periods apply (45 days for the NAPLEX; 30 days for the MPJE, subject to a cap of 5 attempts per jurisdiction).

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2. Foreign Pharmacy Graduate Pathway

Graduates of pharmacy colleges outside the United States and its territories (non-ACPE accredited institutions) must complete a rigorous multistep equivalency process administered jointly by the National Association of Boards of Pharmacy (NABP) and the Tennessee Board:

[ Foreign Pharmacy Degree ] 
          │
          ▼
[ FPGEE + TOEFL iBT ] ──► [ FPGEC Certification ]
                                    │
                                    ▼
                   [ Register as TN Pharmacy Intern ]
                                    │
                                    ▼
                   [ Complete 500 TN Intern Hours / 6 mo ]
                                    │
                                    ▼
                   [ Pass NAPLEX & TN MPJE (Pass/Fail) ] ──► [ Full TN Pharmacist License ]

Step-by-Step Foreign Graduate Pathway

1. FPGEC Certification: The candidate must obtain the Foreign Pharmacy Graduate Examination Committee (FPGEC) Certificate from NABP by:
   • Documenting foreign pharmacy educational credentials equivalent to a U.S. degree.
   • Passing the Foreign Pharmacy Graduate Equivalency Examination (FPGEE).
   • Achieving passing scores on the Test of English as a Foreign Language - Internet-Based Test (TOEFL iBT) (minimum passing thresholds: Reading 22, Listening 21, Speaking 26, Writing 24).
2. Internship Registration: Following FPGEC certification, the graduate must apply for registration as a pharmacy intern with the Tennessee Board.
3. Tennessee Internship Completion: Under Rule 1140-01-.04(1)(c), a foreign pharmacy graduate must complete 500 hours of pharmacy internship in Tennessee within a period of six (6) consecutive months. This is a distinct, shorter requirement than the 1,700-hour standard applied to graduates of recognized U.S. colleges of pharmacy — a frequently tested contrast.
4. Licensure Examinations: Must pass both the NAPLEX and the Tennessee MPJE (each reported Pass/Fail).

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3. Licensure by Reciprocity (License Transfer)

Pharmacists licensed in another U.S. state, commonwealth, or territory may obtain a Tennessee license through reciprocity (license transfer) under T.C.A. § 63-10-310(e) and Rule 1140-01-.03(4) and (6):

• NABP Electronic Licensure Transfer Program (e-LTP): Applications must be initiated through NABP's electronic license transfer clearance process.
• Substantially Equivalent Standards: The original jurisdiction of licensure must have maintained qualifications and examination standards substantially equivalent to Tennessee's standards at the time of original licensure.
• Good Standing: The applicant's licenses in all other jurisdictions must be active, in good standing, and unencumbered by outstanding disciplinary suspensions or revocations.
• Tennessee MPJE: Every reciprocity candidate must sit for and pass the Tennessee MPJE. Because the MPJE is jurisdiction-specific, an MPJE result cannot be transferred from another state — only NAPLEX and UMPJE results are transferable.
• Score Transfer vs. Reciprocity: Under Rule 1140-01-.03(6), an applicant initially licensed elsewhere may, at the Board's discretion, transfer a NAPLEX score taken in another state; however, if the applicant has been licensed for twelve (12) or more months in another state, the applicant must instead apply by reciprocity. No license issues to a reciprocal or score-transfer applicant from a state that denies the same privilege to Tennessee pharmacists.
• Personal Appearance: The Board or Board staff retains the statutory discretion to require a reciprocity applicant to appear for an interview prior to final licensure approval.

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4. Biennial License Renewal & Grace Period

Renewal Mechanics

• Renewal Frequency: Pharmacist licenses in Tennessee are renewed on a biennial (two-year) cycle.
• Expiration Date: The license expires on the last day of the licensee's birth month every two years (or the biennial anniversary of initial issuance).
• Renewal Fee & Application: Licensees must complete the renewal notice, pay the non-refundable renewal fee, and attest to compliance with continuing education requirements.

The 60-Day Grace Period and Practice Status

• Grace Period (T.C.A. § 63-1-107): The statute provides a 60-day grace period following the license expiration date during which a pharmacist may renew by paying the standard renewal fee plus a mandatory late penalty fee.
• Unlawful Practice Warning: Practicing pharmacy on an expired license is illegal. Even though the 60-day grace period allows renewal without formal license reinstatement proceedings, practicing while expired exposes the pharmacist and the pharmacy permit to formal disciplinary charges and civil penalties.
• Automatic Invalidation: If a license is not renewed by the expiration of the 60-day grace period, the license is deemed invalid and expired, requiring formal reinstatement application.

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5. Continuing Education (CE) Mandates: Rule 1140-05

Continuing education requirements are promulgated under Tenn. Comp. R. & Regs. Chapter 1140-05:

Board Business Meeting Attendance Credit

Separately from Rule 1140-05, the Tennessee Board of Pharmacy has by Board policy authorized live CE credit for attending a regularly scheduled public business meeting of the Board:

• Full-Day Meeting Attendance: Awards 2 hours of live CE credit.
• Designated Half-Day Attendance: Awards 1 hour of live CE credit.
• Important Exam Limitation: This credit is a Board authorization, not a codified provision of Rule Chapter 1140-05 — do not answer an exam item by citing a rule number for it. A pharmacist appearing before the Board in a disciplinary or compliance matter is not attending as a CE participant.

Specialized and Targeted CE Mandates

1. Opioid and Controlled Substance CE: Under Rule 1140-03-.17(15), pharmacists who hold a current federal DEA registration must complete a minimum of two (2) hours biennially of continuing education related to controlled substance prescribing, which must include instruction in the Department of Health's treatment guidelines on opioids and chronic pain. These hours count toward the mandatory 30-hour CE requirement.
2. Vaccine Administration / Immunizer CE: Pharmacists who administer vaccines under a protocol must:
   • Maintain current certification in Basic Life Support (BLS) or Cardiopulmonary Resuscitation (CPR) through live, in-person hands-on training.
   • Complete a minimum of 2 contact hours of immunization-related CE during each biennial renewal cycle.
   • Note: Rule Chapter 1140-05 does not award general CE credit for the CPR/BLS certification itself; count only the ACPE-accredited immunization CE.

Continuing Education Audits and Penalties

• Random Auditing: The Board conducts random audits of renewing pharmacists. Selected licensees must submit verifiable proof (NABP CPE Monitor transcript or provider certificates) within 30 days of receiving an audit notice.
• Audit Non-Compliance Penalties: Failure to document required CE hours results in:
  • Monetary civil penalties assessed under Rule 1140-08.
  • A mandatory requirement to make up deficient CE hours (which cannot be credited toward the current renewal cycle).
  • Disciplinary reprimand or probation.

CE Exemptions and Waivers

Under Rule 1140-05-.01(2), no pharmacist is required to complete CE during a two-year license cycle if the pharmacist presents proof that, during all or part of that cycle, the pharmacist was:

• Enrolled in a recognized academic program pursuing a pharmacy degree, an MD, a DO, a DDS, or an advanced/graduate degree in a health-related science;
• Participating in a pharmacy residency or fellowship program; or
• Engaged in a course of study leading to certification as a nurse practitioner or physician assistant.

Separately, Rule 1140-05-.01(3) lets the Board waive the CE requirement "upon a showing of emergency, illness, or other good cause." Rule 1140-05-.02(3) requires the licensee to produce proof of completed CE hours upon request of the Board.

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6. Inactive Status vs. Retired License & Reactivation Protocols

Reactivation Requirements from Inactive Status

If a pharmacist desires to transition from inactive back to active status, the requirements scale directly with the duration of inactivity:

[ Inactive < 1 Year ] ────────► Pay active renewal fee + complete all outstanding CE for cycle

[ Inactive 1 to 5 Years ] ────► Pay active renewal fees + complete accumulated CE (30 hrs, ≥15 live) 
                                + Pass Tennessee MPJE

[ Inactive > 5 Years ] ───────► Pay active fees + complete accumulated CE (30 hrs, ≥15 live) 
                                + Pass Tennessee MPJE 
                                + Retake NAPLEX (or prove active practice in another state)
                                + Complete 160–320 supervised internship hours 
                                + Personal appearance before the Board

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7. Practical Exam Scenarios

Scenario 1: Live CE Calculation

Case: Dr. Alvarez completes 20 hours of online asynchronous webinar modules (ACPE code ending in 'H') and 10 hours of live interactive seminars (ACPE code ending in 'L') during her two-year renewal period. Her total CE is 30 hours. Is she compliant? Legal Analysis: No. Under Rule 1140-05-.01, a Tennessee pharmacist must complete at least 15 hours of live/interactive CE. Although her total is 30 hours, she only completed 10 live hours. She is 5 live hours deficient and subject to audit failure, fines, and disciplinary action.

Scenario 2: Reactivation After 3 Years Inactive

Case: Dr. Vance placed his Tennessee license on inactive status 3 years ago while working in an administrative non-clinical corporate role. He now accepts a clinical pharmacist position in Nashville and applies to reactivate his license. Legal Analysis: Under Board regulations, because his license was inactive for more than 1 year but less than 5 years, Dr. Vance must: (1) pay all required active renewal fees; (2) complete 30 hours of approved CE (with at least 15 live hours); and (3) sit for and pass the Tennessee MPJE. He is not required to retake the NAPLEX or complete new internship hours because his inactivity did not exceed 5 years.