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Why compounded prescriptions get rejected

The usual reasons a pharmacy sends a compounded prescription back, what federal rules sit behind them, and what to check before you sign.

By the TrueRoute team · · 5 min read · General information, not legal or medical advice

Why compounded prescriptions get rejected

In short. Most compounded prescriptions that come back do so for a handful of fixable reasons: the order is really office stock, the prescriber is not licensed where the patient is, a required element is missing, or the product cannot be sent for that patient. Each can be caught before the prescriber signs.

1. It is office stock, written as a prescription

A 503A compounding pharmacy works from prescriptions for individual patients. FDA says compounding under section 503A “must be based on the receipt of a valid prescription for an identified individual patient.” A prescription written to put product in the office, with no real patient behind it, does not fit that. Office-use supply is its own kind of order, from a 503B outsourcing facility, which FDA says may supply a health care provider without a prescription for an identified patient.

Prevent it: keep patient prescriptions and office-use purchases as separate orders from the start.

2. The prescriber is not licensed in the patient’s state

The prescription travels with the prescriber’s licence. When the patient lives, or the order ships, somewhere the prescriber is not licensed, a pharmacy will usually not fill it. Licences are issued by state boards; NABP keeps the contact list for every state board of pharmacy, and each medical board keeps its own public lookup.

Prevent it: confirm each prescriber’s state licences before an order is written for a patient in that state, and keep expiry dates current.

3. A required element is missing

A prescription that leaves out the patient’s details, the strength, the quantity, the directions or the prescriber’s identifying details will be returned so it can be completed. Pharmacies also commonly need the prescriber’s contact details to reach them with a question. Every round trip adds days.

Prevent it: treat every element as required, and have the prescriber review the whole prescription, as it will be sent, before signing.

4. It looks like a copy of an approved drug

Section 503A says a compounder must not compound “regularly or in inordinate amounts any drug products that are essentially copies of a commercially available drug product.” FDA’s guidance ties the difference to a change that the prescriber has determined will produce a significant difference for the patient. A pharmacy that cannot see a patient-specific reason may ask for one, or decline.

Prevent it: when a compounded version is chosen for a patient-specific reason, the prescriber should record that reason. Whether a given order meets the rule is for the prescriber, the pharmacy and your counsel.

5. The product cannot be sent for that patient

Not every product is available for every state, and some products are not compounded at all. Finding that out after the prescriber has signed and the clinic has paid is the most expensive way to learn it.

Prevent it: know before ordering whether a product can be sent to that patient’s state.

Where TrueRoute fits

TrueRoute is ordering software, not a pharmacy, and never prescribes. Orders are filled by licensed pharmacies in our network. Before a prescription is signed, TrueRoute checks the prescriber’s licence in the patient’s ship-to state as attested, requires the elements a prescription must carry, refuses controlled substances, and says in words when a product cannot be sent for a patient, all before anything is charged. The prescriber reviews the complete prescription with its total, and what is signed is frozen as the record the pharmacy receives. A patient prescription and an office-use purchase are separate orders.

What is a 503A compounding pharmacy? · Choosing a compounding pharmacy · How it works

Questions

  • Why was a prescription for office use sent back?

    A 503A pharmacy compounds against a prescription for an identified individual patient; FDA says compounding under 503A must be based on the receipt of a valid prescription for an identified individual patient. Product for the office is a different order, from a 503B outsourcing facility, not a prescription written to stock a cabinet.

    What a 503B outsourcing facility is

  • What can we check before the prescriber signs?

    That the prescriber is licensed in the patient’s state, that every required element is present (patient, product, strength, quantity, directions and the prescriber’s identity), and that the product can be sent for that patient at all. In TrueRoute those checks run before anything is signed or charged, and a product that cannot be sent says why in words.

  • Does TrueRoute change a prescription to get it through?

    No. The prescription is the prescriber’s. TrueRoute never edits what was signed or swaps a product to make an order pass; it shows what is missing or blocked so the prescriber can decide.

Sources

  1. FDA, “Prescription requirement under section 503A of the Federal Food, Drug, and Cosmetic Act”, final guidance for industry (December 2016)
  2. FDA, “FDC act provisions that apply to human drug compounding under sections 503A and 503B”
  3. FDA, “Compounded drug products that are essentially copies of a commercially available drug product under section 503A”, final guidance (January 2018)
  4. NABP, “About safe.pharmacy” (state board of pharmacy contacts and licence checks)

Rules change. Confirm what applies to your clinic with your state board of pharmacy, your medical board and your own counsel.

Catch it before it is signed.

Tell us what you order today, and we will show you the checks on your own products.