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Let CDR Resource Center review your application prior to submission. This review could save you literally months of processing time with the State.
Since the changes made to the new State of Florida Resident and Non-Resident Wholesale application in March 2017, many Clients need assistance understanding the State requests and questions on the application. Needless to say, this application has never been an easy one, and it shouldn’t be easy. Our goal is to keep our wholesale supply chain clean and keep adulterated products out of the State of Florida. Our families do live here and may need to use these drugs in times of illness.
Yes, there is a new application. Download it here. If the application you are using does not say “Eff Date: March 2017” in the bottom left margin, it is the old application and the State will not accept it.
The number one issue that Clients have is interpreting what is being requested by question 8 on page 12 of the application, “Does the applicant have credentialing policies and procedures as required by s. 499.0121(15), FS.” If yes, provide a copy. If no, why?
If you turn to 49 of my manual (see link information to order the manual), Due Diligence of Purchasers, you will see that this question applies to those wholesalers who distribute controlled substances, schedules II and/or III to physicians and/or pharmacies in the State of Florida. If your Company does not distribute CII or CIII drugs into Florida to physicians or pharmacies, this question should be answered “No.” Policy attached, “No.” Explanation attached, “Yes.” Please state something similar, Our Company does not have a DEA# and does not distribute controlled substances or Our Company has a DEA but does not sell CII or CIII products to physicians or pharmacies, we only sell to other wholesalers, etc.
One other change that warrants a bit of understanding is on page 5 the Normal business hours and the operating hours. So why was this added?
If you turn to page 42 of my manual, FS 499.012(15)(c)3, it states: the CDR
“Must be physically present at the establishment during normal business hours, except for time periods when absent due to illness, family illness or death, scheduled vacation, or other authorized absence.” (emphasis added).
Keep in mind whatever hours you list under “normal business hours” the CDR must be present and working in the capacity of the CDR. The law does not define Operating Hours. So the best advise is to just follow the paragraph on the application and answer the question to the best of your ability.
You can contact CDR Resource Center at www.CDRResourceCenter.com or call 954-257-9000. By Email Info@cdrresourcecenter.com.
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