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Regional · North America

US compounding rules and how they changed

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VN
v.nascimentoTL223 Sep 2024#1

US compounding rules and how they changed — setting out what I have, and where I think it stops being reliable.

Reporting a regional experience with the date and the jurisdiction attached, because an undated regional account is the least useful thing in this category.

What happened, in order, with the stated reason at each step. The stated reason is the part that generalises; the outcome is not.

12 likes 22mo
JV
j.vandermolenTL3Regular25 Sep 2024#2

Picking up the opening post: that is the part I would want checked first.

Compounding pharmacies: pharmaceutical compounding of a drug not on the FDA shortage list is substantially constrained. The landscape changed when supply normalised. Current compounding availability is limited.

1 like 22mo
BC
b.correiaTL226 Sep 2024#3

Anyone reporting an outcome should give the stated reason rather than the verdict. The reason is the part somebody else can use.

One case, stated as one case.

0 likes 22mo
BS
buffer_shiftTL1Member27 Sep 2024#4
b.correia, post #3: Anyone reporting an outcome should give the stated reason rather than the verdict. The reason is the part somebody else can use. One case, stated as one case. Go to post

Pharmacy practice varies between pharmacies within the same city, so two honest accounts can be entirely different.

I keep a log of this specifically because memory is unreliable about it.

23 likes in reply to #3 22mo
AE
a.eriksenTL228 Sep 2024#5

Prior authorisation criteria are usually published by the payer and reading them before the appointment changes the outcome more than anything else does.

This is where my knowledge stops and I would rather mark the edge than blur it.

3 likes 22mo
RA
r.arbuthnotTL1Member29 Sep 2024#6

This follows post #3 rather than contradicting it.

Say which country and which state or province. Regulatory position, availability and practical route can all differ within the same continent and frequently do.

0 likes 22mo
CS
c.serranoTL230 Sep 2024#7

I read post #3 twice before replying, because I had assumed the opposite.

Nothing in this subcategory is medical or legal advice, and the clinicians posting here say so on their own account.

32 likes 22mo
TN
t.nardoneTL3Regular1 Oct 2024#8
c.serrano, post #7: I read post #3 twice before replying, because I had assumed the opposite. Nothing in this subcategory is medical or legal advice, and the clinicians posting here say so on their own account. Go to post

That is a fair summary of where the discussion has got to.

16 likes in reply to #7 22mo
TV
t.verhoevenTL22 Oct 2024 · edited#9
r.arbuthnot, post #6: This follows post #3 rather than contradicting it. Say which country and which state or province. Regulatory position, availability and practical route can all differ within the same continent and frequently do. Go to post

Compounded preparations and authorised products are different regulatory categories with different oversight, and conflating them produces most of the confusion here.

Someone should write this up properly, and it should probably not be me.

1 like in reply to #6 22mo
LC
l.chevalierTL3Regular3 Oct 2024#10

Emotional language in an appeal does not help, however justified it is. The reviewer is checking criteria and the job is to make them checkable.

I am reporting what happened, not recommending it.

0 likes 22mo
DB
d.barrosTL24 Oct 2024#11

Post #9 is right about the mechanism and I think understates the practical bit.

Cross-border purchase: buying in the US and bringing to Canada or vice versa involves both countries' import rules. The medication is legal but crossing borders with it is regulated.

That is the practical version. The rigorous version is longer and says the same thing.

30 likes 22mo
HK
h.karlsenTL25 Oct 2024#12

Coming back to post #10, because the follow-up matters more than the original answer.

Cross-border purchasing raises both a legal question and a practical one, and the legal one is yours to establish for your own jurisdiction.

0 likes 22mo
NV
n.vogelTL26 Oct 2024#13
MI
m.ivaturiTL26 Oct 2024 · edited#14
buffer_shift, post #4: Pharmacy practice varies between pharmacies within the same city, so two honest accounts can be entirely different. I keep a log of this specifically because memory is unreliable about it. Go to post

Both are useful and different. The account tells you what happens in practice; the criterion tells you what to write.

It cost nothing to check and would have cost something not to.

10 likes in reply to #4 22mo
SF
s.ferreiraTL27 Oct 2024#15

Post #12 answers the question as asked. The question underneath it is different.

Date every claim in this subcategory. Positions here have moved repeatedly and old posts are read as current.

22 likes 22mo
OC
o.cousineauTL3Regular8 Oct 2024#16

Where a manufacturer runs a direct supply route, that is a commercial arrangement rather than a regulatory change, and it can end.

0 likes 22mo
RM
r.mwangiTL29 Oct 2024#17

Appeals succeed more often than people expect when they answer the stated criterion point by point and include nothing else.

Reading it back, the second half matters more than the first.

1 like 22mo
CN
c.niemelTL3Regular10 Oct 2024#18
c.serrano, post #7: I read post #3 twice before replying, because I had assumed the opposite. Nothing in this subcategory is medical or legal advice, and the clinicians posting here say so on their own account. Go to post

Shortage status determines what compounding is permitted in some jurisdictions, which is why the availability question and the compounding question are linked.

I would want to see it done twice before believing it once.

6 likes in reply to #7 22mo
CR
compounding_ruthTL4Pharmacist10 Oct 2024#19

The public assessment documents published at approval are free, detailed and largely unread here.

A partial answer, offered because a partial answer beats none.

0 likes 22mo
ZO
z.okonkwoTL211 Oct 2024#20

Clear enough that I do not think I have a follow-up, which is unusual.

2 likes 22mo
IB
i.beaulieuTL212 Oct 2024#21

That matches what I have seen, for whatever a single anecdote is worth.

0 likes 22mo
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NLoughranTL3Regular13 Oct 2024#22

Private insurance gaps: some people have private insurance but medication is not covered. Manufacturer assistance programmes are the main resource for cost reduction.

I would not lead a decision with this, but I would not ignore it either.

23 likes 21mo
MA
m.amankwahTL213 Oct 2024#23
s.ferreira, post #15: Post #12 answers the question as asked. The question underneath it is different. Date every claim in this subcategory. Positions here have moved repeatedly and old posts are read as current. Go to post

Worth separating two things that post #19 runs together.

Cost comparisons should state whether they include the device and the dispensing fee, because those differ between routes and between states.

6 likes in reply to #15 21mo
VS
vial_slopeTL3Regular14 Oct 2024#24

This follows post #23 rather than contradicting it.

The denial letter is the specification for the appeal. It states a criterion and the job is to demonstrate that criterion in the letter's own language.

1 like 21mo
VO
v.okonkwoTL215 Oct 2024#25

Compounded preparations and authorised products are different regulatory categories with different oversight, and conflating them produces most of the confusion here.

Adding it because I spent an afternoon working it out and nobody should have to twice.

0 likes 21mo
T
TamburelloTL2Member16 Oct 2024#26

Emotional language in an appeal does not help, however justified it is. The reviewer is checking criteria and the job is to make them checkable.

The claim is narrower than it sounds, and deliberately so.

31 likes 21mo
LL
l.lundgrenTL216 Oct 2024#27
i.beaulieu, post #21: That matches what I have seen, for whatever a single anecdote is worth. Go to post

Post #23 and I disagree about the size of the effect, not about the direction.

Cost comparisons should state whether they include the device and the dispensing fee, because those differ between routes and between states.

10 likes in reply to #21 21mo
I
IMainwaringTL3Regular17 Oct 2024#28
s.ferreira, post #15: Post #12 answers the question as asked. The question underneath it is different. Date every claim in this subcategory. Positions here have moved repeatedly and old posts are read as current. Go to post

Cross-border purchasing raises both a legal question and a practical one, and the legal one is yours to establish for your own jurisdiction.

For what it is worth, the same held on the two occasions I checked.

3 likes in reply to #15 21mo
RM
r.molnarTL218 Oct 2024#29

Where I part company with post #27, and it is a narrow parting.

Where a compounding pathway existed and closed, posts describing it stay in the archive and should be read with their date attached.

24 likes 21mo
TS
taper_shiftTL3Regular18 Oct 2024#30
buffer_shift, post #4: Pharmacy practice varies between pharmacies within the same city, so two honest accounts can be entirely different. I keep a log of this specifically because memory is unreliable about it. Go to post

Post #27 is the version of this I will quote in future. One addition.

Nothing in this subcategory is medical or legal advice, and the clinicians posting here say so on their own account.

11 likes in reply to #4 21mo