We continue to look back at the previous year to highlight what you may have missed with our DSCSA 2025 Ten Count. Ten Count Consulting's list of top DSCSA moments and stories from the year.

Product Verification Tools Show

Immediate Value in Protecting Patients

‍

‍

‍

‍

The benefits of DSCSA started to more clearly emerge this past year after 11 years of work by the industry to implement all the foundational components of DSCSA, including labeling, data integrations, new systems, new processes, and new procedures. A key objective of the law and guidance is to allow for the detection of harmful drugs if they do enter the supply chain and enable rapid response to remove harmful drugs from the supply chain to protect patients. State and federal agents play a critical role in making this a reality, and this was clearly demonstrated through events that unfolded in 2025, which led to state pharmacy and distribution regulatory agents relying on Product Verification as a new tool in investigations.

The Arkansas Board of Pharmacy, in collaboration with other involved states, leveraged NABP's (National Association of Boards of Pharmacy) platform known as Pulse by NABP to perform a near real-time check of the encoded data to quickly receive a positive or negative check if the data matches original packaging data. The story was outlined in several publications, including this Securing Industry article which clearly showed the benefits of the verification tool. In this instance, a negative verification helped confirm the product was potentially counterfeit and dangerous.

The verification of the product identifier in this instance was performed leveraging US GS1 Implementation Guides, global GS1 Standards, and the widely adopted US verification router service (VRS) that solution providers have developed. The service is maintained leveraging a forum coordinated by the HDA (Healthcare Distribution Alliance) called the  HDA VRS Provider Network

It is essential to acknowledge that, although requirements related to product verification are clearly outlined in the law and guidance, how each trading partner chooses to comply with these requirements is largely left to each organization to determine and address. We are aware of trading partners who have elected to leverage e-mail as their method for requesting or responding to product verifications in an electronic interoperable manner within the time frames outlined. However, we highly encourage all manufacturers and repackagers to work with their technical associates and solution providers to consider leveraging the VRS network approach, as it is clearly becoming the proven and widely adopted method for compliance.

What Benefits are there to leveraging the VRS network?

• Method that has become most widely adopted, with estimates of over 80% of verifications facilitated by the VRS and growing.
• Significantly faster than e-mail or other manual approaches, with responses often happening within 1 second.
• State regulators can leverage the network and provide as well as receive contact information in the messaging.
• Solution providers manage secure connections and vetting of participants through policies and/or business agreements.

‍What Challenges Remain?

• Stabilization will continue to take time. Groups like HDA VRS Provider Network continue to coordinate policy improvements to help improve the network. The network runs leveraging a distributed look-up directory that requires active involvement from managing solution providers. With any distributed data, there is always a risk of sync issues that can be caused by human or system errors. We hope that more solution providers will see the benefits of specialization to allow neutral groups like NABP to become facilitators of a simpler directory.
• Access to Verification Requests needs to grow to all regulators and trading partners, including the smallest pharmacies. While this service is growing, there is still a significant jump expected in adoption when requirements for small dispensers take full effect on November 27th, 2026.
• Manufacturers and Repackagers need to be more proactive in managing the performance of the network. While leading trading partners have gotten actively involved, it is important that manufacturers and repackagers, as primary stewards of their product quality and safety, drive the functionality and stability of the network. Solution providers play a key role, but any successful system is reliant on well-informed and active business users and stakeholders. We encourage trading partners to consider joining the quarterly meeting conducted by HDA that is open to all US Supply Chain trading partners.
• Dispensers must ensure they have a plan to be able to perform verification requests when required. While many of the requirements of DSCSA can be managed with partners such as distributors, GPOs, or 3PLs, product verification requires the actual party with physical possession to make determinations based on well-established and trained procedures.

‍

We are excited to see DSCSA coming into full effect as it provides significant capabilities for those preventing and investigating dangerous product. While it is clear that systems and processes will take years to fully stabilize, the industry came together in a big way in recent years to help make DSCSA a reality. We appreciate the efforts by all trading partners, solution providers, trade organizations, standards groups, consulting peers, and regulators working daily on DSCSA.

Contact Ten Count Consulting to learn how we can help you navigate DSCSA requirements and protect the health of your customers.

Stay tuned to our blog over the coming days as we share the remaining 8 highlights of 2025!

‍

Previous Posts:

Number 10- The End of Key DSCSA Exemptions

‍

‍