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Regional · North America · continued

US compounding rules and how they changed posts 31–60

This is a continuation of a long topic, addressed by post number rather than by page. Start at post 1.

MK
m.kjaerTL219 Oct 2024 · edited#31

That reframing is the whole thing. The facts I already had.

0 likes 21mo
M
microgramsTL2Regular20 Oct 2024#32
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

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

That has held every time I have looked, which is not the same as always.

4 likes in reply to #15 21mo
EM
e.mbekiTL221 Oct 2024#33
m.amankwah, post #23: 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. Go to post

The arithmetic in post #30 is right; the assumption feeding it is the part to check.

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

17 likes in reply to #23 21mo
RH
revision_historyTL3Wiki editor21 Oct 2024#34

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

33 likes 21mo
JI
j.ivaturiTL222 Oct 2024#35

Formulary position changes on a schedule that is published in advance, which means a decision made now may be answering last year's formulary.

That holds for the case as described. Change the assumptions and it may not.

0 likes 21mo
BO
b.oylerTL1Member23 Oct 2024#36
i.beaulieu, post #21: That matches what I have seen, for whatever a single anecdote is worth. Go to post

Post #32 put the caveat in the right place and I want to underline it.

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

That is the version I use. It may not be the version that is correct.

1 like in reply to #21 21mo
MR
m.ramosTL223 Oct 2024#37
r.molnar, post #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. Go to post

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.

Anyone who has looked at this more carefully, please correct the record.

11 likes in reply to #29 21mo
DN
desiccant_notesTL2Member24 Oct 2024#38

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

I would be interested in a counterexample if anyone has one.

25 likes 21mo
SR
s.roosTL224 Oct 2024#39

Post #38 is right about the mechanism and I think understates the practical bit.

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 21mo
GV
g.valckenaereTL3Regular25 Oct 2024 · edited#40

This is the first time the answer has come with its own limits attached. Appreciated.

0 likes 21mo
L
LundqvistTL2Member26 Oct 2024#41

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

A weak preference rather than a position.

0 likes 21mo
JS
j.solbergTL226 Oct 2024#42

Building on post #41 rather than restating it.

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

26 likes 21mo
K
KForsbergTL2Member27 Oct 2024#43

Everything in post #41 holds. The case it does not cover is the one I have.

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.

12 likes 21mo
SH
s.hartmannTL228 Oct 2024#44
l.lundgren, post #27: 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. Go to post

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

Happy to be the one who is wrong here if it settles the question.

4 likes in reply to #27 21mo
TW
t.waldenstrmTL2Member28 Oct 2024 · edited#45

Post #41 and I disagree about the size of the effect, not about the direction.

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

0 likes 21mo
FE
f.espinozaTL229 Oct 2024#46

Taking post #45 at face value and following it one step further.

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

0 likes 21mo
M
MakinenTL2Member30 Oct 2024#47
s.hartmann, post #44: Private insurance gaps: some people have private insurance but medication is not covered. Manufacturer assistance programmes are the main resource for cost reduction. Happy to be the one who is wrong here if it settles the question. Go to post

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

I am aware this is the third time this month I have made this point.

18 likes in reply to #44 21mo
SR
s.radichTL230 Oct 2024#48
EL
e.lehtinenTL231 Oct 2024#49

Worth separating two things that post #45 runs together.

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

A qualification I should have led with rather than closed on.

27 likes 21mo
HF
h.ferrariTL231 Oct 2024#50

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

The rule of thumb is fine; the edge cases are where it earns its keep.

13 likes 21mo
B
BirkelandTL3Regular1 Nov 2024#51

Reading rather than answering, but this is the post I would point somebody at.

9 likes 21mo
AK
a.kravchenkoTL22 Nov 2024#52
m.amankwah, post #23: 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. Go to post

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.

The strength of my opinion here exceeds the strength of my evidence.

21 likes in reply to #23 21mo
CT
cannula_traceTL3Regular2 Nov 2024#53

The arithmetic in post #52 is right; the assumption feeding it is the part to check.

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

The number is defensible. The precision I gave it is not.

0 likes 21mo
VR
v.rautioTL23 Nov 2024#54

Answering the question post #50 raises rather than the one it answers.

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.

Flagging that the sources on this are thinner than the confidence in the thread suggests.

0 likes 21mo
G
GSwinburneTL1Member4 Nov 2024#55

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.

14 likes 21mo
AK
ar.kravchenkoTL24 Nov 2024#56
compounding_ruth, post #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. Go to post

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

28 likes in reply to #19 21mo
CI
citation_indexTL2Member5 Nov 2024#57

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

Caveat: everything above assumes the paperwork is what it says it is.

0 likes 21mo
MO
m.oyelaranTL25 Nov 2024#58

Everything in post #54 holds. The case it does not cover is the one I have.

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

I am confident about the direction and much less about the magnitude.

2 likes 21mo
EM
endpoint_marginTL2Member6 Nov 2024 · edited#59
v.okonkwo, post #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. Go to post

This follows post #56 rather than contradicting it.

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

The conclusion is tentative; the arithmetic underneath it is not.

2 likes in reply to #25 21mo
RC
r.coelhoTL26 Nov 2024#60
desiccant_notes, post #38: Both are useful and different. The account tells you what happens in practice; the criterion tells you what to write. I would be interested in a counterexample if anyone has one. Go to post

Thank you for taking the time. That was more work than a reply usually is.

10 likes in reply to #38 21mo