Tips & More

CompoundingCompliance.com

Tips:


"Office Use" of medications, in general, refers to "limited" or "reasonable" quantities and for administration in the office, institution or hospital--No dispensing by doctor to patients.  Best to inquire with the State Board of Pharmacy of your home state and the state you are shipping into as to the legality of selling to, and/or shipping to a practitioner's office.

 

The DEA also does not recognize compounded, controlled substance medications ordered for "Office Use" or "Office Administration." Patient-specific only, controlled substance prescriptions must be delivered directly to patients--No shipping to doctor's office.  (Verified in conversation with DEA inspectors, 8/2010).

Title 21 Code of Federal Regulations Section 1306.04 Purpose of issue of prescription

 

Much has changed in DEA regulations for 2010.  Best to read the entire Pharmacist's Manual:

 

DEA Diversion Control Pharmacists Manual (Prescription Requirements section)


 

The 3 states that do not require a Non-Resident Pharmacy Permit are Pennsylvania, Georgia and Massachusetts.


Kentucky, Georgia, Arkansas and Oklahoma allow the "office use" of compounded medications except for controlled substances as written in their State Rules, which also parallels the Federal DEA, patient-specific, controlled substance prescription requirement. 


Ohio and Missouri strictly forbids the "office use" of compounded medications and Ohio requires pharmacies to deliver medicines directly to patients. (Verified by telephone conversation with the Ohio Board of Pharmacy, 3/2010)


Texas  and South Carolina allow the "office use" of compounded medications, but requires a specific contract between pharmacy and practitioner.  The details required in the contract are listed in the Texas and South Carolina pharmacy rules links found on the individual State's page.

Eight States require the Pharmacist-in-Charge of a licensed out-of-state pharmacy to also hold a license to practice pharmacy in that particular State:  Arizona, Oregon, Kentucky, Arkansas, Tennessee, Louisiana, Nebraska, and Virginia.

Eleven States schedule HCG as a controlled substance:  California, Colorado, Connecticut, Idaho, Louisiana, Minnesota, Nevada, New York, North Carolina, Pennsylvania and Rhode Island.

 

The FDA also has not approved HCG for weight loss.


Eight States schedule HGH as a controlled substance:  Arizona, Colorado, Idaho, Minnesota, New York, Oregon, Rhode Island and West Virginia.  The DEA also monitors and oversees the illicit use of human growth hormone, which has a very narrow prescribing indication.  HGH also cannot be compounded.

US Nurse Practitioner Prescribing Law (Sign up for free medscape service)