‘Uneven Readiness’ Seen for Supply Chain Law

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The latest HDA Research Foundation “Serialization Readiness Survey” says there continues to be uneven readiness as supply chain partners prepare for the 2023 Drug Supply Chain Security Act (DSCSA) implementation milestone. “FDA’s granting of enforcement discretion in 2020 until 2023 for certain wholesale distributor and dispenser requirements, while very beneficial for the industry, has resulted in a perception among some trading partners that they can defer necessary 2023 investments and onboarding to the deadline,” the survey says.

HDA reports that 2% of manufacturers are still unsure when they plan to exchange data with wholesale distributors. “While this number is down from 16% last year,” it says, “it is concerning. An additional 32% of manufacturers are currently sending serialized data to their wholesale distributor customers upon shipment and 66% plan to do so by 11/2023.”

The consultants say the top reported concerns regarding overall implementation were the governance of the interoperable system, collaboration with trading partners, and technical challenges. “Moreover,” it says, “dispenser knowledge of DSCSA requirements continues to be an additional highlighted concern for distributors. The perceived knowledge across industry segments continues to be low, especially among independent pharmacies. As the open-ended comments indicated, educating dispensers with accurate information is critical and will continue to present issues going forward.”

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