Expert Q&A: How Pulse by NABP Is Bridging the Gap Between Regulators, Manufacturers, and Pharmacies in the DSCSA Era

In this interview, Pharmacy Times speaks with Josh Bolin, senior adviser of the National Association of Boards of Pharmacy (NABP) and senior vice president of Pulse by NABP, and John Kirtley, PharmD, pharmacy board director from the Arkansas Department of Health, about Pulse—a new digital platform launched in early 2025 that enables pharmacy regulators, manufacturers, distributors, and dispensers to verify the legitimacy of drug products by scanning their 2D data matrix codes in real time.

Bolin and Kirtley emphasize that NABP’s neutral, state regulator–focused role gives Pulse unique credibility across the supply chain, and they note that the product verification tool will be made available to pharmacies at no cost later in the summer of 2026, ahead of the upcoming Drug Supply Chain Security Act (DSCSA) compliance milestone in November.

Pharmacy Times: Can you introduce yourself and explain your current role?

Josh Bolin: I’m Josh Bolin. I serve as senior adviser at the National Association of Boards of Pharmacy, as well as senior vice president for Pulse by NABP.

John Kirtley, PharmD: I’m John Kirtley. I’m currently the pharmacy board director from the Arkansas Department of Health.

Pharmacy Times: Can you start by giving us a quick overview of what Pulse by NABP is and why it was developed?

Bolin: Pulse by NABP is a digital platform that the association developed to help our member boards of pharmacy as they work to protect public health and patient safety. The best way to think about Pulse is that it is a directory for all the trading partners in the supply chain—manufacturers, wholesalers, and pharmacies—as well as a directory for all the products that move through the supply chain. Those 2 directories, taken together, enable our members, when they’re out in the field, to scan the 2D data matrix of a product and to ask questions about that product: understanding whether the identifiers on that product were affixed by the manufacturer, or trying to understand who has bought or sold that product previously. We built this to help with the implementation of the…DSCSA. We’ve been working on this for a number of years now and ultimately launched the first features of the platform at the beginning of 2025.

Kirtley: For me, Pulse is a tool that we’ve needed for a long time—not only in the investigative space, but just as a pharmacist. I can literally take my phone and scan a product if I have any reason to suspect that it might not be valid, or if something might have happened with the provenance of that product. It can either immediately tell me that it’s good, or flag that there’s a potential problem and get me in touch with the right people to discuss it.

Pharmacy Times: How has your board been using Pulse in practice? Can you walk us through a real-world scenario where the platform helped you initiate or respond to a trace request?

Kirtley: Absolutely. For the Arkansas State Board of Pharmacy, as soon as we heard that Pulse was potentially going to be a tool we could use, we were interested. We were ready to do beta testing, or whatever we could, to have it at our disposal. In the real world, we did receive notification about a potentially suspect product—it was an injectable GLP-1 [glucagon-like peptide-1 receptor agonist] that had occurred in another state, with a related issue here in our state. It was in a pharmacy about an hour from our office. We immediately dispatched one of our inspector-investigators, who is a pharmacist by training, to go to that store. When we scanned that product—and we realized we were in a kind of beta-test mode at that time because it was still in early development—by putting it into production and scanning that product, it was immediately identified as a suspect product. The very next day, we had email and phone contact with the appropriate people at that drug manufacturer and confirmed that it was not a legitimate product.

Pharmacy Times: Before Pulse, what did the process of drug tracing and supply chain communication look like for your board, and how has that changed?

Kirtley: Having been here a little over 20 years, I have faced multiple instances where we would identify medications we thought had been diverted out of the normal chain of distribution—that potentially ended up in a pharmacy where something seemed illegitimate when it came in from a gray-market wholesaler, or while working with other law enforcement entities, including the Arkansas State Police and the DEA [US Drug Enforcement Administration]. We would see stock bottles of medications, and we could get down to the lot number and expiration. Sometimes we would get lucky enough that there would be a pharmacy sticker from receipt of the medication that could help us, especially on the law enforcement side of these cases. But it was a very onerous process, and it was very difficult to establish where drugs might have left the legal chain of distribution and ended up on the street or in the illegitimate chain. With this tool, when I’m working a case with the DEA or with local law enforcement, and we come across an actual manufacturer’s bottle, I can take this tool and scan it. We can trace the provenance of that product and confirm that it was a legitimate product manufactured by a specific company, distributed through a specific channel, and we can get all the way to the point of identifying which store it came from. We know that store had an armed robbery or a break-in overnight, and it actually connects the criminals to the case—we can establish the unknown loss of drugs and where they had gone. In the past, I have spent weeks trying to figure out where a drug had come from, or where it had exited the legitimate chain of distribution, with no success at all. The real difficulty for us is that there are so many people potentially in this equation, and it’s really hard to identify who we would reach out to specifically, because the legal distribution side of a manufacturer or wholesaler is not necessarily the same line of people we need to speak with when a diversion has occurred somewhere down the chain.

Pharmacy Times: Pulse currently serves manufacturers, distributors, dispensers, and regulators. What does expanding access to pharmacies and other dispensers look like, and what is the timeline or road map for that growth?

Bolin: The very tools that John has been describing—being able to utilize product verification to make a quick determination about the legitimacy of a product from its identifiers—are actually tools contemplated under the law. Pharmacies have an obligation to perform product verifications if they identify something that might be suspect or illegitimate. Because of what we’ve seen in Arkansas and in other states—where suspect products are still making their way into our legitimate supply chain, and very often it is the independent and community pharmacies that are targeted with deals that are too good to be true—NABP has committed to making that product verification tool available at no cost for pharmacies. The reason we want to do that is that the DSCSA only works if all participants in the supply chain are utilizing the tools it provides. Looking ahead to November of 2026, when the next compliance milestone for pharmacies goes into effect, and they should be fully complying with the DSCSA, our intention is to make that tool available to pharmacies later this summer, so they have time to work it into their existing processes and get familiar with it. The hope is that they won’t have to use it that often—because they’re only purchasing from authorized trading partners they’ve already vetted—but it is a tool we believe they should have access to, which is why we’re making it available at no cost.

Kirtley: I would add that when I’ve personally been in pharmacies and have shown them this tool, or when our inspector-investigators have, the pharmacists immediately see the value. The question is usually, “How can I get that?” I basically have to tell them it’s not a matter of if, but when. Pharmacists want this tool because every once in a while, you have something that doesn’t seem right about a medication, or a tote of medications comes in, and something looks like it may have been damaged. Just knowing that you could scan that product to validate it immediately—right in the palm of your hand—is an incredibly valuable tool.

Pharmacy Times: Patient safety is at the core of DSCSA. In your view, how does a platform like Pulse translate better supply chain communication into tangible protections for patients at the pharmacy counter?

Bolin: One of the things that the DSCSA did—which can seem kind of technical and complex, but is actually a mechanism to unlock more value throughout the supply chain—is the serialization of products down to the saleable unit. That’s not something that existed before. As John mentioned, before this, a regulator or even a pharmacy could only get down to the lot level when tracing a product. Now, because each product has a unique serial number that travels with it through the supply chain, that really unlocks a lot of potential and should give pharmacies, wholesalers, and manufacturers more confidence that products are only going where they should be. From a patient perspective, everybody is kind of familiar with the barcodes on products today, and they may not know that additional layer of protection is there—but it is. It really does strengthen the supply chain and opens up other opportunities for supply chain visibility. Potentially, there’s a future down the road where patients could even scan a barcode to understand whether the product they’ve obtained is coming from a legitimate source. I think we’re a little ways off from that, but it is possible because of serialization and the GS1 global standards that are being implemented. DSCSA really should get the credit for putting that in place and opening up those opportunities for the future.

John Kirtley: I would echo exactly what Josh has said. With serialization, it raises the bar tremendously for anyone trying to introduce counterfeit drugs into the market, because it’s a different level. Back in the day, we would say, “Well, it has a hologram on it, and only a few people had the ability to make a hologram,” or point to a specific type of font or packaging detail. In the past, we have seen examples where fake drugs actually looked better than real drugs—maybe the tablet looked slightly higher quality, or the packaging had a higher-quality sticker because it hadn’t been handled as much. Serialization moves us from “it might look good enough” to “Does it have a valid serial number that actually links up to where it should be?” It is an incredible tool for patient safety, all the way to the counter.

Pharmacy Times: NABP describes its position as neutral and independent within the supply chain. Why is that neutrality important to the credibility and adoption of Pulse, and how does it shape how the platform is built and governed going forward?

Bolin: Great question. One of the interesting roles that NABP has stepped into is this: as DSCSA is being implemented—a law that was enacted in 2013, and here we are in 2026—the way the law was structured really put a lot on industry to figure out how things were going to be governed and how things were going to move forward. The FDA, as the agency, is sometimes very limited in terms of how it can engage, so it was left to a lot of industry discussion. Industry deserves tremendous credit for the progress that was made, but one thing that was likely lacking throughout that process was a neutral entity representing the state regulators. The states really weren’t part of the equation, even though the states are the ones responsible for—and out in the field doing—the work of driving compliance with DSCSA. We were able to step in from the state perspective, as those who are actually doing the work in the field. I think that lent NABP credibility: We’re coming at this from the same perspective that the law is trying to achieve, which is patient safety. That patient safety angle allowed us to step in and be a neutral party that could bring regulated entities together to help solve this common goal.

Kirtley: I would just add that, from a state board of pharmacy and pharmacist perspective, NABP has long been seen as a trusted leader in our profession. It’s my professional membership organization as a board of pharmacy, but it’s also the organization that has, for many years, maintained our national licensure exam for all pharmacists. By being the neutral party in between, they’ve really helped to bring both sides of this equation together—connecting pharmacists and pharmacy board regulators directly to the manufacturers—where we are all in the same boat, going the same direction, working together, rather than trying to figure out who to reach out to or what connection could be made.