We have been contacted a few times, about this thread. First let it be known that this post, and all of our posts, are not "Verified Legal" opinions, but are personal interpretations. That being said, there seems to be some confusion about what we previously said. To make it as clear as we can. There are only 2 choices for any OP that wants to do business in Florida. They must either become full-fledged pharmacies themselves, and be licensed as such, or they must divest all traces of being a pharmacy.

There is no in-between position. Either the OP must BE a pharmacy, or all pharmacy related issues must be independently handled by a seperate, licensed pharmacy. The state of Florida will decide if a site is an "Internet Pharmacy", based upon how the site presents itself, not by whether or not drugs actually originate from the site owner's physical location.

To avoid being targeted as a pharmacy, the OP can not list any drugs names and/or prices on their site. The OP can not charge for medications, and the OP should never have possession of the prescriptions. Prescription transfer should be directly from the physician to the pharmacy, with no intermediate stops. This would generally be accomplished via FAX, from the MD's office to the pharmacy.

The OP's only business should be to collect, and store patient records, and to establish appointments, for the patients, with the physicians. These activities are be acceptable, because none of them are related to the practice of pharmacy, but should the OP have ANYTHING to do with the medications, they will step over the line, and into trouble. Unfortunately, there are a large number of OP's that have transformed into a "hybrid" form. They try to handle ALL aspects of the business, recordkeeping, appointments, charging for everything at once, and shipping.

Our opinion may not be acceptable to some OP's, because it means that they will have to drastically and permanantly, change how their businesses operate. Unfortunately, we see no alternatives, either they will need to comply, or they will need to cease servicing Florida patients. They can comply either by getting licensed, or simply letting their pharmacies do ALL of the pharmacy work (prescription receipt, filling, charging and shipping).

The reason for this post is that our phone discussions always seem to get to the same point, every time. The calling OP will be struggling to find a method to maintain their current "hybrid" business, and we will be saying that we believe that this is just not possible, without the OP actually getting that "Internet Pharmacy" license. It is a hard pill to swallow. Get a license, divest all pharmacy related activities, or stop servicing Florida patients, all are bitter choices.