Pharmacy law changes. A book does not. This page is the log that sits between the two: every change to the federal or state law the UMPJE tests that is recent enough to still be wrong in study material, with the primary source so you can check it yourself, and a note of which DocTayo material it affects.

If you own a DocTayo guide or question bank, this page is the fastest way to tell whether your copy is current. Corrections are free to anyone who bought the material — ask for the current edition with the email address you purchased under.

Everything here is checked against the regulation, the Federal Register, NABP or the relevant board before it is posted. Nothing is taken from a summary or another prep site. If you find something on this page that is wrong, please say so — that is worth more to the next candidate than it costs me to fix.

The Ultimate UMPJE Master Guide revised again

Materials update

The guide was audited against primary sources and reviewed again in further rounds. 233 of its 501 pages changed, and four keyed answers moved. Below is what changed, grouped so you can see quickly whether it touches something you have already studied. If you bought the guide before October 20, 2026, your copy is the earlier edition.

Every item says what the earlier edition got wrong or left out, then what the book says now. Page layout and numbering are unchanged, so your page references still hold.

Practice questions: answers that changed

Re-check these if you already studied them.

  • Four keyed answers moved: question bank Q182 (B to A) and Q183 (B to A), Exam 1 Q95 (C to A), and Exam 3 Q36 (A to B).
  • Question bank Q61, Q62, Q171 and Q186 were reworded so the stem has one defensible answer; their keyed answers are unchanged.
  • The October 20 final round moved no keyed answer.

Practice questions: reworded, answer unchanged

  • Exam 1 Q20 (interchangeable biosimilars) now asks how an interchangeable biosimilar differs from other biosimilars, because the old stem had two true options.
  • Exam 2 Q73 (child-resistant packaging) now asks which agency sets the standards.
  • Three question stems that could not be answered as written, and several others that allowed a second defensible answer, were tightened.
  • Question bank Q84 (opioid-use-disorder prescribing): options now describe the three-day rule as a dispensing rule. Q176 (Form 222 errors): option C now says a defective form is retained and replaced.
  • Exam 3 Q98 option B: dispersal of controlled substances is meant to obstruct theft or diversion.

Final round, October 20, 2026

  • Employment bar in 21 CFR 1301.76(a): it has no waiver clause. “Absent a waiver” is removed from seven places.
  • Pseudoephedrine: the only logbook exemption is a single package of no more than 60 mg (21 USC 830(e)(1)(A)(iii)). The book no longer says pediatric liquids are exempt. Page 39.
  • Sodium fluoride child-resistant packaging exemption: the limit is 110 mg per package, not 264 mg (16 CFR 1700.14(a)(10)(vii)). Pages 32, 195 and 480.
  • Repackaging beyond-use date: the book now says that for a pharmacy acting as dispenser the default is the earlier of the manufacturer’s expiration date or one year from packaging (USP <7> Labeling), and points commercial repackagers to USP <1178>. Page 30.

DEA and controlled substances

  • Financial, sales and pricing data may be inspected only with the registrant’s separate written consent, and a warrant does not supply it (21 USC 880(b)(4)). The book had said “consent or a warrant.”
  • The three-day rule in 21 CFR 1306.07(b) is a dispensing rule, not an administering rule. 1306.07(d) reaches any Schedule III–V narcotic approved for the purpose, not buprenorphine alone. The same wording is fixed on the quick-reference pages.
  • A red “C” on a Schedule III–V paper prescription makes it readily retrievable (21 CFR 1304.04(h)(4)). The prescription filing systems are restated to match.
  • Schedule V: federal law sets no refill cap and no six-month expiration. The book had applied both in several places.
  • Hydrocodone combination products left Schedule III in 2014 and are Schedule II.
  • Marijuana scheduling updated for the April 2026 order.
  • Loss of state authority is a ground for DEA to suspend or revoke, not an automatic termination (21 CFR 1301.52(a)).
  • Timely renewal under 21 CFR 1301.36(i); interstate relocation treated as a modification; same-state condition on the prescribing-only satellite exception.
  • Schedule II partial fills: statutory origin corrected.
  • Transfers: a Schedule II prescription may not be transferred for refill purposes; an unfilled electronic prescription may be transferred once for initial filling.
  • Schedule II change list is a state-law question; DEA no longer publishes a federal list of permitted changes.
  • Form 222: a power of attorney is not required whoever signs; an error does not require a VOID marking (21 CFR 1305.15), and a defective form is retained and replaced. Requisition procedure rewritten and Form 222a removed; blank forms come through DEA’s secured network or a Division Office.
  • Central recordkeeping notice goes to the Special Agent in Charge by registered or certified mail, in triplicate; records may move 14 days after notice.
  • The 72-hour refill printout is a delivery deadline (the daily printout goes to each pharmacy), not a verification deadline (21 CFR 1306.22(f)).
  • An unreceived emergency follow-up prescription is reported to the nearest DEA office, not the Field Division Office.
  • The fax-as-original exception for a compounded Schedule II narcotic turns on the route (parenteral infusion), not on home infusion (21 CFR 1306.11(e)). The cheat-sheet mnemonic is now “Infusion, Institution, Hospice.”
  • Audio-only authority for opioid use disorder is 21 CFR 1306.51 and is permanent, with its six-month cap stated; it is not part of the temporary extension in 1307.41.
  • DEA check digit in Exam 3 corrected; dronabinol covered by formulation.
  • Schedule V refill and expiration statements on the quick-reference and review pages now say Schedule III–IV only; a Schedule III prescription is void six months after issue.
  • NTP registration is annual. Form 41 is no longer shown as sent to DEA. A registration is not transferable without DEA’s written consent.

Compounding, USP standards and repackaging

  • USP 795 default beyond-use dates have four categories keyed to water activity: nonpreserved aqueous 14 days refrigerated, preserved aqueous 35 days, nonaqueous oral liquids 90 days, other nonaqueous forms 180 days.
  • Stability data can extend a default BUD only to 180 days; only a USP-NF monograph carries it further.
  • Immediate-use CSPs: administration must begin within 4 hours of the start of preparation; the 2023 chapter no longer frames immediate use as an emergency provision.
  • The ante-room must be ISO 7 where it serves a negative-pressure buffer room.
  • NIOSH 2024 hazardous drug list.
  • USP 797 Category 1, 2 and 3 turn on the assigned BUD and the requirements met, not on the room.
  • Compounding exemptions: compounded drugs are outside DSCSA, and the 503A and 503B cGMP and shortage-list statements were corrected to match the statute. The 503A frequency qualifier is corrected.

FDA, drug approval and the supply chain

  • DSCSA small dispenser date corrected. Verification of saleable returns is a wholesale distributor’s duty.
  • REMS: the element menu includes packaging and safe disposal; an ANDA REMS is not subject to the assessment timetable. The cheat-sheet REMS mnemonic goes from five elements to six, and the timetable for assessments is described as always required for an NDA or BLA REMS.
  • The confirmatory-trial duty belongs to accelerated approval. Dispersal storage must obstruct theft or diversion.
  • Orphan drugs: the definition has two prongs, and the cost-recovery prong is stated correctly (an orphan threshold of 200,000 patients, or a disease with no expected cost recovery).
  • Biosimilars: only an interchangeable biosimilar may be substituted without prescriber intervention; first-interchangeable exclusivity ends at the earliest of three triggers (1 year, 18 months, 42 months, depending on the event); the four-letter suffix is absent on older and transition products.
  • Drug Facts ordering comes from 21 CFR 201.66, not the CARES Act.
  • Future 12-digit NDC format noted. PREP Act authority corrected.

Packaging, privacy, counseling and other

  • Child-resistant packaging: there is no institutional exemption; the book now describes institutional dispensing as outside the requirement only where staff administer the medication. The 16 CFR 1700.14(a)(10) exemptions cover oral dosage forms only.
  • Medication Guide on request is a duty owed to the patient.
  • HIPAA: media notice applies above 500 residents of a State; HHS notice at 500 or more individuals.
  • An intern may counsel under direct supervision. The book no longer attaches a minimum purchaser age to pseudoephedrine.
  • A bioequivalence scenario with an internally inconsistent confidence interval was corrected.

Layout and bookkeeping

  • The “500 facts” chapter held 501; it is now 500.
  • Score bands no longer put 76% in two places.
  • A deadline table that was out of order and several mis-sorted or mislabeled appendix tables were fixed.
  • The five Part III forms are described as 100-question scored-content practice exams, not full-length mock exams.
  • The monospace rows of three decision-tree pages, which earlier edits had redrawn too small, were restored to their original size.
  • Exam format: the book now says the exam is computer-based with no going back, 120 questions in 2.5 hours, and no longer calls it adaptive.
  • The index cites chapters and the table of contents was rebuilt to match.

You do not need to ask for the corrected copy. The download link in your original receipt points at the current edition and stays valid for a year from purchase, so re-opening that link gives you the corrected book. If the link has expired or you cannot find the receipt, email with the address you bought under.

Affects: Ultimate UMPJE Master Guide

The DSCSA small dispenser exemption now runs to November 27, 2027

Regulation

FDA's exemptions page, checked on October 20, 2026, gives the small dispenser exemption an end date of November 27, 2027. November 27, 2026 has not disappeared: it is the date on which the 25-employee headcount is measured.

The eligibility test is at the owning company level: 25 or fewer full-time employees licensed as pharmacists or qualified as pharmacy technicians, counted as of November 27, 2026. Eligibility is self-determined and no notice to FDA is required.

The exemption is partial. It covers certain enhanced drug distribution security requirements only. Authorized trading partner verification, six-year data retention, suspect and illegitimate product handling and saleable returns verification all continue to apply.

Affects: Ultimate UMPJE Master Guide · Domain 1 — Pharmacy Practice

Citation: FD&C Act § 582
Source: FDA, Exemptions under the Drug Supply Chain Security Act

DEA removes the X-number from the face of the prescription, and the 14-day administration window becomes 45 days

Regulation

DEA conformed part 1306 to the end of the DATA-waiver regime. 21 CFR 1306.05(b), which required a buprenorphine prescription for maintenance or detoxification treatment to carry the practitioner's DEA-issued identification number, is removed and reserved. Section 1301.28 went with it.

Section 1306.04(c) and (d) no longer require the drug to be FDA-approved specifically for maintenance or detoxification treatment, and no longer limit the prescription to a “qualifying practitioner.” Section 1306.07(d) lost the same two conditions.

Section 1306.07(a) now reads “a narcotic drug in Schedule II” where it used to read “listed in any schedule,” so the narcotic-treatment-program registration requirement for direct administration or dispensing is confined to Schedule II.

Section 1306.07(f)(5): where a pharmacy delivers a controlled substance to a practitioner to administer by injection or implantation, it must be administered to the named patient within 45 days of the practitioner's receipt, not 14. The statute has said 45 days since the Consolidated Appropriations Act, 2023; the regulation caught up in 2026.

The three-day rule in 1306.07(b) was not touched.

Affects: Ultimate UMPJE Master Guide · Domain 2 — Medication Use Process · Domain 3 — Regulatory Authority

Citation: 21 CFR 1306.04(c), (d); 1306.05(b); 1306.07(a), (d), (f)
Source: 91 FR 34754, Implementation of the SUPPORT Act: Dispensing and Administering Controlled Substances for Medication-Assisted Treatment, effective July 9, 2026

Some marijuana products move to Schedule III

Regulation

A Justice Department order places FDA-approved marijuana products, and products subject to a qualifying state medical-marijuana license, in Schedule III. Everything else stays in Schedule I.

The order adds 21 CFR 1308.13(g)(2) through (4): marijuana in an FDA-approved product or subject to a state medical marijuana license, marijuana extract in an FDA-approved product, and naturally derived delta-9-tetrahydrocannabinols in either. Everything else stays in Schedule I at 1308.11(d)(23).

The blanket statement that marijuana is Schedule I regardless of state law is no longer accurate, and neither is the opposite overcorrection. A state program still does not create federal authority for a product outside the order.

This is separate from the broader Schedule I-to-Schedule III rescheduling proposed at 89 FR 44597. That proceeding has not been finalized, and its administrative hearing was stayed by the Chief Administrative Law Judge on September 29, 2026.

Synthetically derived THC is outside the CSA definition of marijuana and outside this order. FDA-approved cannabidiol was removed from the schedules entirely in 2020 and is not a controlled substance.

Affects: Ultimate UMPJE Master Guide · Domain 3 — Regulatory Authority

Citation: 21 CFR 1300.01; 1308.11(d)(23), (d)(31), (d)(58); 1308.13(g)(2)–(5)
Source: 91 FR 22714, Rescheduling of Food and Drug Administration Approved Products Containing Marijuana From Schedule I to Schedule III, effective April 28, 2026

DEA narrows who may sign a Form 222 power of attorney, and deletes the triplicate transition rule

Regulation

A technical amendment finished a change DEA began in 2019. A power of attorney to execute DEA Form 222 orders is executed by the registrant — a partner if a partnership, an officer if a corporation — not by whoever signed the most recent registration application. The same amendment removed and reserved 21 CFR 1305.20, the transition provision for the old triplicate form.

Execution takes three sets of signatures, which is the part most study material still leaves out: the registrant, the person receiving the power, and two witnesses. Revocation takes the same.

Any source published before 2026 that says "the person who signed the most recent application for registration or reregistration" is quoting a repealed rule — including DEA's own 2022 Pharmacist's Manual.

Affects: Ultimate UMPJE Master Guide · UMPJE practice bank · Domain 3 — Regulatory Authority

Citation: 21 CFR 1305.05(d)(1)–(3), (e)
Source: 91 FR 13498 (Docket DEA-1005), effective March 20, 2026

EMS agencies get their own registration, and part 1306 gains standing-order authority

Regulation

DEA added 21 CFR 1306.07(g) and (h). An emergency medical services professional of a registered EMS agency may administer — but not prescribe — Schedule II through V controlled substances outside the physical presence of a medical director, where state law allows and under a standing or verbal order.

Paragraph (h) requires the agency to keep a record of the standing or verbal orders at a registered location.

This implements the Protecting Patient Access to Emergency Medications Act of 2017. It is not pharmacy-facing, but it changed the scope section of part 1306 and is the sort of recent amendment an exam writer notices.

Affects: Domain 3 — Regulatory Authority

Citation: 21 CFR 1306.01, 1306.07(g), (h)
Source: 91 FR 5216, Registering Emergency Medical Services Agencies, effective March 9, 2026

Audio-only prescribing for opioid use disorder has its own permanent rule

Regulation

21 CFR 1306.51 lets a practitioner prescribe a Schedule III–V controlled substance approved for opioid use disorder after an audio-only telemedicine encounter. It is a standing authority and does not expire with the temporary telemedicine extension.

The temporary extension at 21 CFR 1307.41 is a separate rule, and it runs only through December 31, 2026. Treating the audio-only OUD authority as part of it is the common mistake.

Section 1306.51 carries its own conditions: a PDMP check before prescribing with the date and time annotated, a six-calendar-month limit from the first prescription unless an in-person evaluation or another 21 U.S.C. 829(e) authority applies, a seven-day supply where the PDMP cannot be reached, and pharmacist verification of the patient's identity against a government photo ID.

It applies only to medications listed in 42 CFR 8.12(h)(2) and approved for the treatment of opioid use disorder.

Affects: Ultimate UMPJE Master Guide · Domain 2 — Medication Use Process · Domain 3 — Regulatory Authority

Citation: 21 CFR 1306.51
Source: 90 FR 6504, Expansion of Buprenorphine Treatment via Telemedicine Encounter (FR Doc. 2025-01049); effective December 31, 2025 after 90 FR 13410

The NIOSH hazardous drug list is now the 2024 list, in two tables

Agency guidance

NIOSH published the List of Hazardous Drugs in Healthcare Settings, 2024 (DHHS (NIOSH) Publication 2025-103) in December 2024. It supersedes the 2016 list and reorganizes it from three tables into two.

Study material that describes three groups — antineoplastics, other hazardous drugs, and drugs with reproductive effects only — is describing the 2016 list.

Containment and assessment-of-risk obligations come from the applicable USP chapter and the actual drug and dosage form, not from the table a drug sits in.

Affects: Ultimate UMPJE Master Guide · Domain 1 — Pharmacy Practice

Citation: USP <800>
Source: CDC/NIOSH, List of Hazardous Drugs in Healthcare Settings, 2024, Publication 2025-103

Schedule II partial fills come from CARA 2016, not the SUPPORT Act

Regulation

The authority to partially fill a Schedule II prescription at the request of the patient or the prescriber was created by section 702(a) of the Comprehensive Addiction and Recovery Act of 2016, which added 21 USC 829(f). DEA implemented it in a rule effective August 21, 2023. The SUPPORT Act of 2018 did not touch partial-fill authority.

Three deadlines, three different triggers. 72 hours from the first partial filling where the pharmacist cannot supply the full quantity. 30 days from the date the prescription was written where the patient or the prescriber requested the partial fill — but 72 hours from issuance if it was an emergency oral prescription. 60 days from the issue date for an LTCF resident or a patient with a documented terminal illness.

The emergency-oral exception is the part most study material leaves out.

Affects: Ultimate UMPJE Master Guide · UMPJE practice bank · Domain 2 — Medication Use Process

Citation: 21 USC 829(f); 21 CFR 1306.13
Source: 88 FR 46984, Partial Filling of Prescriptions for Schedule II Controlled Substances, effective August 21, 2023

The three-day rule is now about dispensing, and the one-day cap is gone

Regulation

A practitioner who is not registered as a narcotic treatment program may dispense — not prescribe — narcotics to relieve acute withdrawal while arranging referral. The limit is a three-day supply at one time, and it may not be renewed or extended.

The old rule let the practitioner administer narcotics and capped it at one day's medication at a time for up to three days. DEA rewrote 21 CFR 1306.07(b) in August 2023; material that still says “administer, one day at a time” is describing the version before that.

Affects: Ultimate UMPJE Master Guide · Domain 2 — Medication Use Process

Citation: 21 CFR 1306.07(b)
Source: 88 FR 53398, Dispensing of Narcotic Drugs To Relieve Acute Withdrawal Symptoms of Opioid Use Disorder, effective August 8, 2023

DEA Form 106 now has a 45-day deadline and must be filed electronically

Regulation

The one-business-day written notice to the DEA Field Division is unchanged. What changed is the form: a complete and accurate DEA Form 106 is due within 45 calendar days of discovering the theft or significant loss, and it must be filed electronically through DEA's Diversion Control Division secure network. Paper is no longer accepted.

Older study material often states the one-business-day notice and then leaves the Form 106 deadline open, or tells you that any stated deadline is a distractor. Since July 2023 there is a real deadline and it is a fair question.

Affects: Ultimate UMPJE Master Guide · Domain 3 — Regulatory Authority

Citation: 21 CFR 1301.74(c), 1301.76(b)
Source: 88 FR 40707, Reporting Theft or Significant Loss of Controlled Substances, effective July 24, 2023

The MATE Act eight-hour training attestation, and who is exempt

Regulation

Most practitioners applying for a DEA registration or renewal that includes controlled substance prescribing authority must attest to eight hours of training on treating patients with opioid or other substance use disorders. It is a practitioner requirement: a pharmacy is not subject to it, and a pharmacist verifying a prescription has no duty to confirm the prescriber's attestation.

The exemption that study material most often garbles is the recent-graduate one. DEA's wording is graduation in good standing from a US medical, dental, physician assistant or advanced practice nursing school within five years of June 27, 2023, where the curriculum included at least eight hours of the required content. That is a fixed window measured from one date — not a rolling five years from whenever the practitioner graduated, which is how it is usually misquoted.

Also deemed to satisfy it: practitioners board certified in addiction medicine or addiction psychiatry. Past DATA-Waiver training counts toward the eight hours. Practitioners who are solely veterinarians are outside the requirement.

The link below is a state-hosted copy of DEA's own letter to registrants; the letter, not the copy, is the source.

Affects: Ultimate UMPJE Master Guide · Domain 3 — Regulatory Authority

Citation: Consolidated Appropriations Act, 2023, Pub. L. 117-328, div. FF, § 1263
Source: DEA letter to registrants, March 27, 2023, signed by Thomas W. Prevoznik, Diversion Control Division

Changes to a Schedule II prescription are a state-law question

Agency guidance

DEA's guidance says that, pending new rulemaking, pharmacists should adhere to state regulations or policy on what may be changed on a Schedule II paper prescription after oral consultation with the prescriber. There is no federal list.

The familiar two-column chart — address, strength, quantity, dosage form and directions on one side; patient name, drug and signature on the other — is a tradition, not a rule. Several states forbid any alteration at all, and where state law is stricter it controls.

What is fixed is fixed by the regulation rather than by a DEA list: 21 CFR 1306.05 requires the prescription to name the patient, to be dated as of the day it is signed, and to be manually signed by the practitioner.

Affects: Ultimate UMPJE Master Guide · Domain 2 — Medication Use Process

Citation: 21 CFR 1306.05(a), (d)
Source: DEA Diversion Control Division guidance DEA-DC-063 / EO-DEA257

The triplicate DEA Form 222 is no longer accepted

Regulation

The single-sheet Form 222 with 20 line items took effect October 30, 2019, and DEA stopped accepting the old triplicate form two years later. Material that tells you to “know both” is out of date.

Worth recognizing only so you can date a source that still teaches it.

Affects: Ultimate UMPJE Master Guide · Domain 3 — Regulatory Authority

Citation: 21 CFR 1305.20
Source: 21 CFR 1305.20 (removed and reserved, 91 FR 13498)

DEA Form 41 is a record you keep, not a form you file

Regulation

The disposal rule made Form 41 the required record of destruction, maintained by the registrant. It is not submitted to DEA unless DEA asks for it, and it is kept for two years.

This one is old enough that it should have washed out of study material by now, and it has not. The rule's own text puts it plainly: a registrant that destroys a controlled substance must maintain a record of the destruction on a DEA Form 41. Maintain, not file.

Affects: Ultimate UMPJE Master Guide · Domain 3 — Regulatory Authority

Citation: 21 CFR 1304.21(e)
Source: 79 FR 53520, Disposal of Controlled Substances (DEA-316), effective October 9, 2014


What this page does not cover

Which states use the UMPJE, and when each state’s own exam closes, is a separate moving target with its own page: Which states use the UMPJE, which recalculates its deadlines as you read it. Exam format and blueprint weighting live on the UMPJE hub.