Nevada Filing Deadlines Are Approaching: What Manufacturers Need to Know

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Drug and device manufacturers doing business in Nevada have upcoming filing deadlines in March, April, and June. By June 1, 2024, compliance officers must sign and submit a certification to the Nevada Board of Pharmacy to confirm that they have conducted an annual compliance audit to ensure compliance with Nevada's marketing code of conduct per Nevada law. Drug manufacturers have additional filing requirements due in March and April related to pharmaceutical sales representative reports and registration forms.

Nevada Marketing Code of Conduct Annual Filing Form

Drug and device manufacturers must file their annual Nevada Marketing Code of Conduct Annual Filing Form by June 1, 2024. This form is available from the Nevada State Board of Pharmacy.

When submitting their forms, companies must certify that they comply with Nevada's marketing code of conduct requirements, which are contained in Section 639.570 of the Nevada Revised Statutes. To make this certification, companies must audit their compliance programs—and they must also certify that this audit has been completed. When submitting their Nevada Marketing Code of Conduct Annual Filing Forms, drug and device manufacturers must also submit:

  • A copy of their current marketing code of conduct;
  • A description of the company’s marketing code of conduct training program for employees and sales representatives; and,
  • A description of the company’s investigation policies for addressing noncompliance with its marketing code of conduct.

Pharmaceutical Sales Representative Registration and Report

In addition to the Nevada Marketing Code of Conduct Annual Filing Form, drug companies must file their annual pharmaceutical sales representative reports by March 1, 2024, and they must file their annual pharmaceutical sales representative registration forms by April 1, 2024. The annual reporting requirement applies to all companies with registered sales representatives conducting covered marketing activities in Nevada.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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