Short answer first, then the reasoning. Resolution therefore closed the doors unevenly, and the asymmetry follows from the bulks lists. For 503B the shortage clause was the only route to these molecules, so that route shut completely. A 503A pharmacy can still argue a doorway via "component of an approved drug" — but only for the substance in the form present in the approved product, which is exactly where the base-versus-salt argument lives, and it does nothing about the copy restriction, which came back into force on resolution.
My pharmacy stopped supplying with three weeks notice and a letter that explained nothing, so I went and read the statute.
What would genuinely help is knowing what actually distinguishes 503A from 503B, in terms of what each may make and from what starting material.
Not looking for reassurance. Looking for the part I have got wrong.
SarahChen_PharmD said:Resolution therefore closed the doors unevenly, and the asymmetry follows from the bulks lists.
SarahChen_PharmD has the substance of this right. The condition it depends on is worth stating. Worth adding the genuine exception, because it is real and narrow: a change made for an identified patient where the prescriber determines it produces a significant clinical difference for that patient. A grid of fixed doses offered to everybody is not that, whatever the intake form says.
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Shop Reference StandardsDr.BariatricHTX said:My pharmacy stopped supplying with three weeks notice and a letter that explained nothing, so I went and read the statute.
Can confirm the pattern Dr.BariatricHTX describes. The shortage clause is the answer to the second question and it is a subtraction rather than an addition. Both exemptions forbid compounding something that is essentially a copy of a commercially available approved product. A product FDA has listed as in shortage is not treated as commercially available, so listing removed the objection that otherwise blocked compounding. It never created a permission; it withdrew a prohibition, which is why it evaporated the moment the supply fact changed.
Adding the clinical framing, because it changes how the question reads.
For compounded supply users considering compounded for the first time: here's a step-by-step guide:
- Get a prescription from your doctor (telehealth counts)
- Research 503B compounding pharmacies with good community reviews
- Verify their FDA registration and inspection history
- Request a COA for your specific compound before ordering
- Start with a 1-month supply to test
- Consider sending a sample to Janoshik for independent verification
- Track your response compared to brand (if you were on it previously)