1.3 License Maintenance, CE Requirements & Renewal
Key Takeaways
- Virginia pharmacist licenses expire annually on December 31, requiring timely renewal with a grace period through January subject to a delinquent late fee.
- Pharmacists must complete a minimum of 15 contact hours (1.5 CEUs) of approved continuing education per calendar year (January 1 through December 31).
- At least 3 of the required 15 annual CE contact hours must be obtained through live or real-time interactive programs; CE hours cannot be carried over to subsequent calendar years.
- Licensees must maintain original CE completion certificates or verified CPE Monitor records for 2 years following the renewal cycle and provide them upon Board audit.
- Inactive license status exempts the pharmacist from annual CE requirements, but reactivation requires submitting 15 hours of CE per inactive year up to a 60-hour cap, plus retaking the Virginia MPJE if inactive for 5 or more years.
License Maintenance, CE Requirements & Renewal
Quick Answer: Virginia pharmacist licenses expire annually on December 31 (18VAC110-21-110). To renew an active license, pharmacists must earn a minimum of 15 contact hours (1.5 CEUs) of approved continuing education per calendar year. At least 3 of the 15 hours must be live or real-time interactive. Virginia law strictly forbids carrying over surplus CE hours into future years. Documentation must be retained for 2 years for random Board audits. Inactive licensees pay annual renewal fees and are exempt from annual CE, but reactivation requires 15 hours per inactive year (up to 60 hours maximum) plus retaking the Virginia MPJE if inactive for 5 or more years.
1. Annual License Renewal Schedule & Deadlines
Under 18VAC110-21-110, every pharmacist license issued by the Virginia Board of Pharmacy must be renewed annually.
Key Dates & Timelines
| Date | Milestone | Regulatory Significance |
|---|---|---|
| December 31 | Annual Expiration Date | All active and inactive pharmacist licenses expire at 11:59 PM. Renewal applications and fees must be received by the Board on or before this date. |
| January 1 – January 31 | Delinquent Renewal Period | Pharmacists who missed the December 31 deadline may renew delinquent licenses by paying the annual renewal fee plus a Board-mandated late penalty fee. |
| February 1 | License Lapsed | Licenses not renewed by January 31 lapse automatically. Practicing pharmacy on a lapsed license constitutes unlicensed practice (§ 54.1-3310). Reinstatement application and board approval required. |
Special Exemption for Newly Licensed Pharmacists
- A newly graduated pharmacist who obtained their initial Virginia license by examination on or after October 1 of a given year is exempt from renewing that license on December 31 of that same year.
- Their initial license remains valid through December 31 of the following calendar year, and their obligation to accumulate continuing education begins on January 1 of that next calendar year.
2. Continuing Education (CE) Requirements
Pursuant to Code of Virginia § 54.1-3314.1 and 18VAC110-21-120, each active pharmacist must complete continuing pharmacy education to ensure ongoing professional competence.
The 15-Hour Mandate & Unit Breakdown
- Minimum Annual Requirement: 15 contact hours of Board-approved continuing education per calendar year (January 1 through December 31).
- Continuing Education Units (CEUs): One CEU equals 10 contact hours. Therefore, 15 contact hours equals 1.5 CEUs.
- Contact Hour Defined: A contact hour represents at least 50 to 60 minutes of organized didactic or interactive instruction.
The Live CE Mandate: 3-Hour Minimum
- A prominent point tested on the Virginia MPJE is the requirement that at least three (3) of the 15 contact hours must be obtained through live or real-time interactive programs.
- What Qualifies as "Live":
- In-person seminars, lectures, workshops, or professional conferences.
- Real-time interactive webinars where participants can ask questions of the presenter and receive synchronous answers during the presentation.
- Self-Study Limit: Up to 12 contact hours may be earned through asynchronous, home-study formats (e.g., recorded on-demand webinars, journal reading with post-tests, monographs). However, self-study cannot be used to satisfy the 3 live hours.
Absolute Prohibition on CE Carryover
- Virginia regulations strictly forbid the carryover of continuing education hours from one calendar year to any subsequent year.
- For example, if a pharmacist completes 25 contact hours in 2026, the 10 surplus hours cannot be credited toward 2027. All 15 required hours must be earned strictly between January 1 and December 31 of each applicable calendar year.
3. Approved Providers & Board-Mandated Topics
Continuing education hours must be obtained through educational providers recognized by the Virginia Board of Pharmacy.
Recognized CE Providers
- ACPE-Accredited Providers: Courses accredited by the Accreditation Council for Pharmacy Education (ACPE) are universally recognized by the Board.
- Category 1 CME: Category 1 Continuing Medical Education programs accredited by the Accreditation Council for Continuing Medical Education (ACCME) or American Medical Association (AMA) that are relevant to pharmacy practice.
- Board-Approved Programs: Non-ACPE educational activities specifically reviewed and approved by the Virginia Board of Pharmacy upon advance petition by the program sponsor.
Board-Mandated Topics Under § 54.1-3314.1
- The Virginia General Assembly grants the Board statutory authority to designate specific required CE subject areas for any given calendar year.
- Publication Deadline: If the Board designates a mandatory topic, it must publish formal notice to all licensees by January 1 of that calendar year.
- Historical & Emerging Focus Areas:
- Opioid prescribing, dispensing, and opioid use disorder (OUD).
- Proper dispensing and administration of opioid reversal agents (naloxone).
- Suicide screening, prevention, and behavioral health referrals.
- Pharmacy law updates and patient safety initiatives.
- When a specific topic is mandated (e.g., a 1-hour opioid safety course), that hour counts toward the overall 15-hour requirement, and counts toward the 3-hour live requirement if completed in an interactive format.
4. Record Retention, Documentation & Audits
Pharmacists must maintain meticulous records of all completed continuing education to comply with Board compliance monitoring.
Retention Timelines & Proof of Completion
- 2-Year Retention Requirement: Pharmacists must retain original certificates of completion or maintain verified electronic records for at least two (2) years following the renewal cycle to which the credits were applied.
- Acceptable Documentation:
- Official certificates of completion issued by an ACPE-accredited provider detailing the participant's name, provider name, date, title, ACPE universal activity number (UAN), and contact hours awarded.
- An electronic transcript generated directly from CPE Monitor (the collaborative electronic tracking service administered by NABP and ACPE).
Random Audits & Disciplinary Penalties
- Each year, the Board conducts random audits of a selected cohort of active licensees.
- Audit Response Deadline: Audited pharmacists must produce verified documentation of their 15 hours within the timeframe specified in the Board's audit notification letter (typically 14 to 30 days).
- Penalties for Falsification / Non-Compliance:
- Renewing a license and falsely certifying completion of CE constitutes fraud and unprofessional conduct.
- Penalties include monetary fines (typically $300 to $1,000+), formal reprimands on the licensee's public profile, and mandatory makeup hours.
- Makeup CE hours completed under a disciplinary order cannot be counted toward the continuing education requirements for the current renewal year.
5. Inactive vs. Active Licensure Status & Reactivation
Pharmacists who do not intend to practice within the Commonwealth may request inactive status or must follow specific statutory steps to reactivate a dormant license.
Pharmacist License Options
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┌────────────────────────────┴────────────────────────────┐
▼ ▼
Active Status Inactive Status
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• Can practice pharmacy in VA • Cannot practice in VA
• Pays annual active renewal fee • Pays reduced annual inactive fee
• 15 CE hours/year (>= 3 live) • 0 CE hours required while inactive
Rules Governing Inactive Status
- Prohibition on Practice: A pharmacist holding an inactive license is strictly prohibited from practicing pharmacy in Virginia. Engaging in dispensing, patient counseling, drug regimen review, or supervision while inactive is illegal unlicensed practice.
- Annual Renewal: Inactive licensees must still submit an annual renewal application and pay a reduced inactive renewal fee by December 31.
- Exemption from CE: Inactive licensees are completely exempt from completing the annual 15 hours of continuing education during the years they remain inactive.
Reactivation Requirements from Inactive Status (18VAC110-21-110)
When an inactive pharmacist decides to reactivate their license to active status, the requirements escalate based on the duration of inactivity:
| Duration Inactive | CE Makeup Hours | Practical Internship Hours | Examination Required |
|---|---|---|---|
| 1 to 4 Years | 15 hours for each inactive year (e.g., 3 years = 45 hours) | None required (unless directed by Board) | None required |
| 5 or More Years | Maximum cap of 60 hours | Minimum 160 hours of practical internship within preceding 6 months under a preceptor | Pass the Virginia law examination (Pass/Fail; UMPJE for applications on or after October 1, 2026) |
Additional Criteria for Extended Inactivity (>= 5 Years)
- If an individual has held an inactive Virginia license for 5 or more years but has been actively practicing pharmacy in another state under an active license throughout that period, the Board may waive the 160-hour internship requirement.
- However, passing the Virginia MPJE is mandatory for all pharmacists seeking reactivation after 5 or more years of dormancy to verify their updated knowledge of Virginia drug laws and administrative regulations.
A Virginia pharmacist completes 22 contact hours of ACPE-approved continuing education during a single calendar year, including 5 hours of live interactive webinars. How many of these hours can the pharmacist carry over to satisfy the continuing education requirements for the subsequent calendar year?
For how long must a Virginia pharmacist retain certificates of completion or verifiable electronic documentation for completed continuing education hours following the license renewal to which they apply?
A pharmacist has maintained an inactive Virginia pharmacist license for six years while working in pharmaceutical marketing out-of-state without practicing patient-centered pharmacy. What are the requirements to reactivate their Virginia pharmacist license to active status?