Compounding: Key Policies and Advocacy

Difficult to Compound Lists and Categories

Advocacy

GFI #256: Compounding Animal Drugs from Bulk Drug Substances

Policy

Advocacy

  • NCPA comments to FDA calling for the rescission of GFI #256 (June 2025)

  • FDA CVM response #2 to NCPA, APC (March 2023)

  • FDA CVM response to NCPA, APC (February 2023)

  • APC/NCPA letter to FDA CVM requesting clarity on compliance/enforcement (February 2023)

USP

Policy

Advocacy

  • NCPA comments to the types of USP’s expert committees (May 2024 )

  • NCPA/APC joint letters to state boards of pharmacy and FDA on delays in stability studies under USP Chapter 797 (April 2024)

Compounded Hormones

Advocacy

Compounding in the States

  • NCPA endorsement of Arkansas HB 1801 that would allow pharmacies to purchase compounded drugs from outsourcing facilities (March 2025)

  • NCPA endorsement of New York S. 3236/A.678 allowing pharmacy technicians to compound (March 2025)

Memorandum of Understanding Addressing Certain Distributions of Compounded Drugs

Policy

  • FDA extension of period before FDA intends to begin enforcing the statutory 5 percent limit (October 2022)

  • FDA's standard MOU [suspended] (October 2020)

FDA Guidances

Policy

Advocacy

  • NCPA comments to prohibition on wholesaling under 503B (August 2023)

FDA's Listening Session on Compounding (May 2024)

Links and Resources

FDA

USP

Other