1.3 Utah Pharmacy License Classes (A–E) & Facility Licensing
Key Takeaways
Utah Code § 58-17b-302 requires a license to act as a pharmacy and creates Class A, B, C, D, and E pharmacies plus the dispensing medical practitioner clinic pharmacy.
A Class A pharmacy is a retail pharmacy located in Utah, including a mail service retail pharmacy located in Utah and a remote dispensing pharmacy.
A Class D pharmacy is a nonresident pharmacy and must have a pharmacist-in-charge licensed in the state where it is physically located (R156-17b-302(4)).
Class E pharmacies, such as third-party logistics providers, analytical labs, and medical gas providers, do not require a pharmacist-in-charge (R156-17b-302(5)).
Each place of business needs its own pharmacy license, and every pharmacy class in Utah renews on September 30 of odd-numbered years (R156-1-308a).
1.3 Utah Pharmacy License Classes (A–E) & Facility Licensing
Pharmacy licensing is a facility-level requirement separate from your individual pharmacist license. The MPJE blueprint tests the registration and licensing of practice settings. Most Utah questions give you a type of business and ask which license class it needs, or whether it needs a pharmacist-in-charge (PIC).
Who needs a pharmacy license (§ 58-17b-302)
A license is required to act as a pharmacy, except for:
- persons exempt from licensure under § 58-1-307;
- a medical cannabis pharmacy operating under Title 4, Chapter 41a (licensed through the cannabis program, not as a pharmacy under Chapter 17b); and
- a licensed dispensing practice under Title 58, Chapter 88, Part 2.
Key structural rules:
- Each place of business requires a separate license. If several pharmacies share one address, each needs its own license.
- DOPL may further define the classes and restrict them to protect the public.
- Each pharmacy must have a PIC unless a rule provides otherwise. Whenever a statute or rule requires or prohibits an action by a pharmacy, the PIC and the owner are both responsible, regardless of how the business is organized.
The license classes
| Class | Statutory definition (§ 58-17b-102) | Examples (R156-17b-302) | PIC? |
|---|---|---|---|
| A | A pharmacy located in Utah authorized as a retail pharmacy to compound or dispense drugs or devices to the public under a prescription | Retail pharmacies; mail service retail pharmacies (located in Utah); remote dispensing pharmacies | PIC or remote dispensing PIC (RDPIC) required |
| B | A pharmacy located in Utah that provides pharmaceutical care to patients in an institutional setting and whose primary purpose is a physical environment for patients to obtain health care; includes closed-door, hospital, clinic, nuclear, and branch pharmacies, and pharmaceutical administration and sterile product preparation facilities | Closed-door; hospital clinic; narcotic treatment program; nuclear; branch; hospice facility; pharmaceutical administration facility; sterile product preparation; DMP clinic; remote dispensing | PIC, RDPIC, or DMPIC required, except pharmaceutical administration facilities and narcotic treatment program pharmacies |
| C | A pharmacy that manufactures, produces, wholesales, or distributes drugs or devices in Utah | Manufacturing, producing, wholesaling, distributing, reverse distributing | Supervised by a designated representative rather than a pharmacist (R156-17b-615(4)) |
| D | A nonresident pharmacy | Out-of-state mail service pharmacy | PIC licensed in the state where the pharmacy is physically located |
| E | "All other pharmacies" | Analytical laboratories; animal control; durable medical equipment providers; human clinical investigational drug research facilities; medical gas providers; animal narcotic detection training facilities; third-party logistics providers; non-drug- or device-handling central prescription processing pharmacies; veterinarian pharmaceutical facilities | No PIC required |
A dispensing medical practitioner (DMP) clinic pharmacy is a closed-door pharmacy inside a licensed dispensing medical practitioner's place of practice. It is listed separately in § 58-17b-302(2)(f).
Note
Physical location decides between Class A and Class D. A mail-order pharmacy in West Valley City is a Class A mail service retail pharmacy. The same operation in Boise, shipping into Utah, is a Class D nonresident pharmacy.
Class C details
A Class C wholesaler or manufacturer need not be supervised by a pharmacist. It must instead have a designated representative who is at least 21, has at least three years of full-time pharmacy or wholesale experience related to prescription drug distribution and recordkeeping, holds a full-time managerial position, is physically present during regular business hours, and serves as designated representative for only one licensee at a time (R156-17b-615(4)). A Class C pharmacy may not share a building with a separately licensed Class A, B, D, or E pharmacy unless the other pharmacy is a third-party logistics provider or the two are in different USPS-recognized suites (R156-17b-615(19)).
Class D (nonresident) requirements
A Class D applicant must, among other things (§ 58-17b-306(2); R156-17b-616):
- verify licensure in good standing in the state where it is physically located;
- submit criminal background checks for each pharmacy manager;
- describe its scope of services and pharmacy care protocol, and submit a copy of its PIC's license;
- sign affidavits that any practitioners it employs who are physically in Utah hold Utah licenses, and that it will follow the pharmacy laws of its home jurisdiction;
- submit its most recent state inspection or NABP Verified Pharmacy Program inspection. A Class D pharmacy that compounds must submit an inspection report conducted within two years before application and again at each renewal (§ 58-17b-308(4)).
Class D pharmacies must give patients a toll-free telephone number to reach a pharmacist or intern for counseling when the prescription is not delivered in person (§ 58-17b-613(2)(a)). Class D compounders follow USP <795> and <797> (R156-17b-616(2)).
Remote dispensing and branch pharmacies
- A remote dispensing pharmacy must be Class A or B, have a Class A or B supervising pharmacy, and be in an "area of need". It may not compound. See Section 13.2.
- A branch pharmacy is licensed as a branch of an existing Class A or B pharmacy. DOPL approves its location based on access to other pharmacies, available staff, and the parent pharmacy's willingness to supervise (R156-17b-614b).
Renewal and the license address
- Every pharmacy class (A, B, C, D, E, and online contract pharmacies) renews on September 30 of odd-numbered years on a two-year cycle (R156-1-308a; § 58-17b-308).
- A pharmacy license is tied to a single, specific address (§ 58-17b-306(3)). Section 1.5 covers moves, ownership changes, and closings.
- A pharmacy that dispenses controlled substances also needs a Utah controlled substance license and a DEA registration (see Section 8.2).
A mail-order pharmacy located in West Valley City, Utah, ships maintenance medications to patients in Utah and neighboring states. Which Utah license class must it hold?
Class D, because it primarily ships prescriptions by mail
Class C, because it distributes drugs across state lines
Class A, because a mail service retail pharmacy located in Utah is a Class A pharmacy
Class E, because it does not serve walk-in customers
A third-party logistics provider in Salt Lake County stores and ships prescription drugs for manufacturers but never dispenses to patients. Which statement about its Utah pharmacy license is correct?
It needs no Utah license because it never dispenses
It is licensed as a Class B closed-door pharmacy with a consulting pharmacist
It is licensed as a Class C pharmacy and must have a pharmacist-in-charge
It is licensed as a Class E pharmacy and does not need a pharmacist-in-charge
A nuclear pharmacy that prepares radiopharmaceuticals for specific patients is located in Nevada and ships doses to Utah hospitals. What Utah license does it need?
A Class D pharmacy license, because a nuclear pharmacy located outside Utah that prepares patient-specific medications is licensed as Class D
A Class B nuclear pharmacy license, because nuclear pharmacies are always Class B
A Class E license, because radiopharmaceuticals are specialized products
No Utah license, because Nevada inspects the pharmacy
Which statement about supervision of a Utah Class C pharmaceutical wholesaler is correct?
It may operate without any responsible individual if it holds a DEA registration
It must have a Utah-licensed pharmacist-in-charge on site during all business hours
It must have a designated representative who meets experience, managerial, and on-site requirements, and it need not be supervised by a pharmacist
Its designated representative may serve up to three licensed wholesalers at once
Sections you finish are checked off in the contents.