Semaglutide and other Medical Weight Loss Drugs: Is it Dispensing?


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Many RNs, APRNs and full practice authority APRNs are wondering if they may prepare vials for patients for the coming month, and send those vials home with patients for the patients to self-inject weekly.  

If you are prescribing medical weight loss drugs and medications and need to know whether you are in compliance with Illinois pharmacy board rules and regulations, call 1818 today. 

Under the Illinois Controlled Substances Act, every person who manufactures, distributes, or dispenses a controlled substance must register with IDFPR. 720 ILCS 570/302(a). APRNs and RNs are not eligible for registration. “Dispensing” means “to deliver a controlled substance to an ultimate user or research subject by or pursuant to the lawful order of a prescriber, including the prescribing, administering, packaging, labeling, or compounding necessary to prepare the substance for that delivery.”  720 ILCS 570/102(p).

For (non-controlled) drugs/prescription medications, we look at the Pharmacy Practice Act and the Nurse Practice Act. RN and APRN scope under the nurse practice act includes administering drugs but not dispensing.

225 ILCS 65/60-35 Nurse Practice Act

(4) Implementing the identified plan, coordinating care delivery, employing strategies to promote healthy and safe environments, and administering or delegating medication administration according to Section 50-75 of this Act.

 Under the Pharmacy Practice Act, dispensing is the practice of pharmacy:

 225 ILCS 85/3:

(d) “Practice of pharmacy” means:

(1) the interpretation and the provision of assistance in the monitoring, evaluation, and implementation of prescription drug orders;

         (2) the dispensing of prescription drug orders;

(m) “dispensing” means the interpretation, evaluation, and implementation of a prescription drug order, including the preparation and delivery of a drug or device to a patient or patient’s agent in a suitable container appropriately labeled for subsequent administration to or use by a patient in accordance with applicable State and federal laws and regulations.

Jordan Matyas

Jordan Matyas

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Jordan Matyas is a lawyer, lobbyist, and Founder of 1818 Legal, an Illinois professional licensing defense law firm he created in 2014. With more than 18 years of experience practicing law, he represents clients in a wide range of legal matters, including professional license defense, administrative law, land use and zoning, and state, local, and municipal law.

Jordan received his Juris Doctor from the University of Illinois — Chicago School of Law and is a member of the Illinois Bar Association.