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Medical Supply Dropship Program: What to Verify Before Joining

What a medical supply dropship program states, and the FTC and FDA rule questions to put to a supplier before joining.

Written and maintained by CASRAI Editorial Board

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General information about how supplier programs and the rules around them work. It is not legal, regulatory or medical advice.

Short answer

A medical supply dropship program is a supplier arrangement in which the supplier fills and ships an order from its own distribution center to the end customer, while the business that took the order stays the point of contact. To judge a program, read what its terms state about who orders, who ships and who is licensed, then ask it to document two rule layers: the FTC shipping-time rule and the FDA device definitions.

Definition and scope

This page covers the program: the terms a supplier publishes or gives to approved accounts. The basics of the model, including the roles of supplier, reseller and manufacturer, are in drop shipping medical supplies, and the broader legal question is in is dropshipping legal. Here the focus is what to read in a program and what to put to it. Variants of the phrase, such as dropship medical supplies, medical supply dropshipping and dropshipping medical equipment, describe the same arrangement.

How a medical supply dropship program works in practice

One distributor program page shows the pattern. McKesson Medical-Surgical’s "Patient Home Delivery" page is aimed at home health agencies, home infusion providers and home medical equipment (HME) providers. Its workflow runs as follows: a physician writes a prescription, the patient contacts an HME provider, the HME provider places the order, and McKesson fills and ships the order from its distribution center. The page states that McKesson can "ship individual orders directly to your patients’ homes," that it will fulfill and ship using UPS, and that it can personalize the packing slip "to keep that customer connection." It also states that the program is "only available for properly licensed customers" and that providers request a business account to get started (page checked 2026-11-01).

Four things are visible in that one page, and they are the questions any program should answer in writing: who places the order, who ships it, whose name is on the packing slip, and who is allowed to join.

Distributor program versus reseller versus manufacturer

Under the FDA’s registration definitions, a wholesale distributor is any person other than the manufacturer or the initial importer who distributes a device from the original place of manufacture to the final seller or user (21 CFR 807.3(t)). Commercial distribution means any distribution of a device intended for human use that is held or offered for sale (21 CFR 807.3(b)). A program run by a distributor therefore sits in a different role from the reseller who takes the order. See medical supply wholesaler for the distributor role and FEI number for how FDA establishment identifiers relate to these roles.

Dropshipping versus holding stock

The trade-offs between shipping from a supplier and stocking inventory are set out in drop shipping vs direct stocking for medical supply distributors.

What to verify before joining a program

The checklist below pairs each question with the text it comes from. It is a list of questions to put to a supplier, not a recommendation of any program.

Question to put to the program Why it matters Source
Who is eligible, and what licensing does the account require? A distributor program page can limit the program to licensed customers and require a business account application. McKesson Medical-Surgical, Patient Home Delivery (checked 2026-11-01)
Who ships, from where, and with which carrier? The example program fills from its own distribution center and ships to the patient by UPS. McKesson Medical-Surgical, Patient Home Delivery
Is the packing slip branded to the ordering business? The example program states the slip can be personalized. McKesson Medical-Surgical, Patient Home Delivery
What shipping time will the supplier support, and what happens when it slips? A seller may not solicit orders by mail, internet or telephone unless it has a reasonable basis to expect to ship within the time it states. If no time is clearly and conspicuously stated, the default is 30 days after receipt of a properly completed order (50 days if the buyer applies for credit at the time of ordering). A revised shipping date needs a reasonable basis, and where a delay passes 30 days or no date can be given, the order is cancelled automatically unless it ships within the permitted period or the buyer consents in writing. 16 CFR 435.2 (checked 2026-11-01)
Does the program repackage or relabel devices? Repackaging or otherwise changing the container, wrapper or labeling of a device package counts as manufacture under the registration definitions when done in order to distribute the device. 21 CFR 807.3(d)(1)
Who is the initial importer for foreign-made products? The registration definitions name the initial importer and the importer as distinct roles from the wholesale distributor. 21 CFR 807.3(g), (x)

The shipping-time row matters for the reseller as well as the supplier: the rule applies to the seller that solicits the order, so a reseller that states a delivery time to its customer should ask what time the supplier can support.

Common misunderstandings

  • "The supplier ships, so the supplier carries all the obligations." The shipping-time rule text is written for the seller that solicits the order, so ask who that is under the program and what the supplier will support.
  • "Any business can join any program." The example program is stated to be available only to properly licensed customers, with a business account request.
  • "A branded packing slip changes who the distributor is." Personalizing a packing slip is a customer-communication feature in the example program; the FDA role definitions turn on who distributes the device and who changes its container or labeling, not on whose name is on the slip.
  • "A directory listing is the same as a program." A program is a set of terms from a named supplier. Ask for those terms in writing.

FAQ

How do you dropship medical supplies?

In the example program: apply for a business account with a supplier whose program accepts your type of business and licensing; take the order from your customer; place it with the supplier, which fills and ships it from its own distribution center; and be able to support the shipping time you state under 16 CFR 435.2. Ask the program who repackages or relabels and who the importer is for products made abroad. The example program is stated to be available only to properly licensed customers, so ask the supplier what licensing its program requires.

What is a medical supply dropship program?

It is the supplier’s set of terms for filling orders on behalf of another business: eligibility, ordering, shipping and packing-slip arrangements. The example above is one distributor’s published version.

Do dropship medical supplies wholesalers need to be registered with the FDA?

This page does not answer that for any specific product. The FDA registration definitions describe the wholesale distributor and repackaging roles; whether a particular establishment must register depends on the rest of the regulation, so ask the supplier to document its status. See FEI number.

Sources

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