The Rise of NABP-Aligned Inspections in Sterile Compounding Licensure: Who Requires, Who Accepts, and Who Doesn’t Mention It
Updated August 19, 2025
Sterile compounding oversight in the U.S. has been moving toward uniform, USP-aligned inspection evidence, especially for nonresident pharmacies shipping compounded sterile preparations across state lines. The National Association of Boards of Pharmacy (NABP) now provides two common frameworks boards lean on:
Verified Pharmacy Program (VPP), a multistate sterile/nonsterile inspection offering used by many boards for nonresident licensure.
Universal/Blueprint Inspection Forms, used directly by some boards or recognized as meeting a consistent, USP-anchored standard set.
But the U.S. remains a patchwork. States fall into three practical buckets.
1) States that Require / Designate an NABP Pathway
In these jurisdictions, NABP is embedded in the official pathway—either the board requires an inspection that uses the NABP Universal/Blueprint framework, or it names NABP as a board-approved designee (often alongside other designated inspectors):
Michigan
What the rule says. Michigan rule R 338.534 for out-of-state pharmacy licensure lists four acceptable inspection sources: (a) the department, (b) NABP-VPP, (c) an accrediting organization, or (d) a resident state agency using the NABP Multistate Pharmacy Inspection Blueprint. That is a direct designation of VPP and Blueprint in rule.
Massachusetts
What the checklist says (nonresident sterile). The Board’s current Pharmacy Application Checklist requires either the state’s NABP-approved sterile compounding inspection form/USP <800> form or a satisfactory inspection using NABP’s Universal Inspection Forms (when the resident state participates in the Blueprint)—or an inspection by a Board-approved inspector using approved sterile forms (e.g., NABP). In practice, the NABP forms/Blueprint framework is baked into the requirement set.
Texas (nuanced—and important)
What the rule page says. For Class E-S (nonresident sterile), Texas requires inspection by TSBP or its designee within the last renewal cycle. TSBP publicly lists approved vendors as its designees; today those include ACHC, NABP, and VaLogic (TSBP may update this list). This is a classic “board or board-approved designee” model—NABP is designated, but not exclusive.
Operational takeaway: If you ship sterile CSPs into MI/MA/TX, plan around an inspection that meets these NABP-anchored expectations. In Texas, you may choose any TSBP-approved designee; in Michigan and Massachusetts, the NABP VPP/Universal-Blueprint pathways are directly recognized in rule or checklist.
2) States that Formally Accept NABP
Here, boards explicitly name NABP (VPP and/or Universal/Blueprint) as one approved option among others (e.g., home-state board inspections or ACHC/PCAB). The precise wording differs, but a current VPP sterile inspection generally meets the inspection evidence requirement if it is within the board’s recency window and demonstrates USP compliance.
Florida
Board action & context: Florida’s Board minutes (Compounding Rules Committee, March 2014) show a vote approving the NABP VPP as an inspection process for nonresident sterile compounding; the agenda packet includes the NABP VPP Sterile Compounding Supplement. This is the board’s formal acceptance of VPP as a pathway (Florida also recognizes other options like FDA/ACHC).
Louisiana
Inspections page / program report: Louisiana requires an inspection within 24 months of renewal and states that NABP inspections are accepted in place of a state inspection; program documentation explicitly lists acceptable compounding inspections as NABP Universal (Blueprint) or ACHC.
Minnesota
Board form: Minnesota states it will accept inspections by the home state, the California Board (for sterile), and/or NABP VPP—explicit, practical acceptance.
North Carolina
Permit page (current): For out-of-state pharmacies, NCBOP accepts either a home-state inspection or an NABP VPP inspection completed within 12 months. If the pharmacy compounds, the inspection must demonstrate USP compliance; deficiencies require corrective-action documentation. This is one of the clearest, current “VPP-accepted” statements in the country.
Ohio
Ohio Board of Pharmacy requires nonresident pharmacies to submit a current inspection report demonstrating compliance with USP standards. Historically, Ohio has accepted home-state board inspections and has also recognized NABP’s VPP inspection as an acceptable pathway for nonresident licensure when it meets the Board’s recency and content requirements. Applicants should confirm acceptable inspection routes in the current renewal/application guidance, as the Board periodically updates its nonresident licensure requirements.
UTAH
Utah’s Board of Pharmacy formally participates in the NABP Blueprint Program and accepts NABP’s Verified Pharmacy Program (VPP) inspection reports for nonresident (mail-service) pharmacies. This means out-of-state sterile compounders shipping into Utah may satisfy inspection requirements with a current NABP VPP report, rather than relying solely on a home-state or Utah-run inspection.
Virginia
Board acceptance (sterile/nonsterile): Virginia requires nonresident pharmacies to submit a current inspection report when applying or renewing. The Board has publicly recognized NABP’s Verified Pharmacy Program (VPP) inspection reports as acceptable evidence of compliance with USP standards, particularly when a home-state inspection report is not available or is insufficient. The Board specifies that inspections must be recent, so applicants should ensure their VPP (or other inspection) falls within the recency window set in Virginia’s nonresident licensure requirements.
Washington
Directive & recognition list: Washington requires nonresident pharmacies to submit an inspection from a program the Commission has deemed “substantially equivalent.” The Commission explicitly used NABP Blueprint criteria in making its determinations and maintains an approved inspection programs directive (updated), which boards/third parties rely on.
Operational takeaway: For these states, a current NABP VPP report (with sterile supplement) is a portable, board-named way to satisfy inspection evidence—often faster and more uniform than stitching together home-state reports.
3) States with No Explicit NABP Mention on Public Licensing Pages
These states rely on board-run inspections, home-state inspection reports, and/or state self-inspection forms—without naming NABP on public pages as a standard pathway. That doesn’t mean they never look at third-party reports; it means NABP is not listed as a formal option in routine licensing materials.
California
Nonresident sterile = Board inspection: The California Board says the sterile compounding license “will not be issued or renewed until the location has been inspected by the board and is found to be in compliance.” No third-party/NABP substitute is offered. A separate Board report to the Legislature documents the scope and costs of California’s out-of-state sterile inspections (hundreds completed since 2014), underscoring the state-run model.
New York
State-run process: Registration and inspection of pharmacies run through the New York State Education Department; New York does not present VPP as a substitute on public pages. (Applicants should plan for state processes and lead times.)
Pennsylvania
Primarily state/home-state driven: Pennsylvania’s public pages emphasize state processes; NABP is referenced in some contexts (e.g., jurisprudence/other services), but there is no current public page giving an NABP VPP substitute for PA licensure inspection. Treat PA as board/home-state inspection driven unless the Board instructs otherwise in a specific case.
Illinois
State sterile self-inspection + board oversight: Illinois uses its own Sterile Compounding Self-Inspection Report tied to USP and state rules; investigators use the report during inspections—no routine VPP substitute on public pages.
Georgia
Georgia requires nonresident pharmacies to provide an inspection report from their home state board of pharmacy (or equivalent regulatory authority) as part of the licensure process. The Georgia Board does not list NABP’s VPP or Blueprint inspections as a substitute pathway on its public licensing materials. In practice, this means applicants should plan around home-state or Georgia-run inspections, with no formal NABP acceptance noted.
South Carolina
Board inspectors by statute; board forms: South Carolina law requires the Board to use its own pharmacist-inspectors to conduct all pharmacy inspections; the Board publishes sterile and non-sterile inspection forms/standards on its site. That’s a clear in-house inspection model, not an NABP-named pathway.
Nevada / Wisconsin (representative)
Each posts state inspection/self-inspection materials and relies on board processes; they do not present an NABP route on routine public licensing pages. (Wisconsin uses self-inspection pre-licensure with an unannounced audit soon after.)
Montana
Where Montana stands: Montana rules and board materials emphasize USP <797> alignment and make sterile compounding policies/records available for inspection by the Board or its designee—but do not publish an NABP-VPP acceptance pathway on public pharmacy licensing pages. Net: no explicit NABP mention.
Operational takeaway: These states, plan on state/home-state inspections and state forms. An NABP VPP report can still help you keep an organized, USP-mapped dossier for other states—but it won’t replace the state’s own requirements.
Practical Guidance for Multi-State Sterile Compounders
Use VPP strategically. In the many states that require/designate or formally accept NABP, a current VPP sterile inspection (with the sterile module) is the cleanest, most portable inspection document you can carry. It also organizes your dossier to the NABP Universal/Blueprint structure that many regulators expect.
Mind the recency windows and USP mapping. Florida and Virginia, for example, have board-specified recency windows, and Louisiana uses ≤24 months for renewal eligibility—these are common patterns. Align your VPP timing with renewal clusters.
Texas nuance matters. Texas is board-or-designee. NABP is one approved vendor, but ACHC and others are also approved. Always confirm the current vendor list on TSBP’s site before scheduling.
Expect state-specific add-ons. Even with VPP, states may require PIC self-inspections, product lists, video/site elements, or local attestations (e.g., South Carolina’s board forms; California’s state-run inspection). Treat VPP as your foundation, then add the state-specific overlay.
Bottom Line
There is no state where NABP is the only legally permissible inspector for pharmacy sterile compounding—but a growing set of states either require/designate NABP-anchored frameworks (Michigan/Massachusetts) or board-approved designees including NABP (Texas).
As of August 2025, NABP lists 19 states participating in the Blueprint Program. These include states across the Midwest, South, and East Coast (e.g., Michigan, Massachusetts, North Carolina, Virginia, Louisiana, Utah, etc.). The Blueprint means these boards either use NABP’s Universal Inspection Form or have “crosswalked” their own inspection forms to meet Blueprint standards
Several states publish no explicit NABP pathway (California, New York, Pennsylvania, Illinois, Georgia, South Carolina, Nevada, Wisconsin, Montana), favoring board/home-state inspections and state forms.
For national operators, the winning approach is to build to USP <797>/<800>, keep a portable VPP inspection current, and maintain a state-by-state overlay for timing and local add-ons. Your licensing stays predictable, and your dossier speaks the same language everywhere.
Ready to Expand Your Reach?
If multi-state pharmacy licensure is your goal, starting with an NABP-aligned inspection sets you up for success. Restore Health Consulting LLC can conduct a gap analysis against the NABP Blueprint standards, identify compliance gaps, and guide you through targeted remediation — so your pharmacy is inspection-ready and positioned for smooth licensure across state lines.