Compounding is an important treatment option used every day by practicing veterinarians. We need to ensure the needs of animal patients and their doctors are met which is why the AVMA is very carefully considering whether or not our compounding policies should be revised, and if so, to what extent. Therefore, later in March, we will be sharing any proposed revisions to our compounding policies with AVMA members and will give our members at least 30 days to review and comment on them. AVMA is sensitive to the need to prevent unintended consequences, so it is critical to have both general member input and input from volunteer governance entities (which often include representatives of other species organizations and disciplines) in the review of the two compounding policies. Upon consideration of member feedback and fundamental concepts recognized by our interested volunteer governance groups (who volunteer their time on AVMA entities designed to review member needs, scientific literature, and existing laws and regulations and bring expert opinions together), the Executive Board will be asked to consider any recommended policy revisions. Any proposed revisions will likely be discussed by the Executive Board in early summer.
Congress is anticipated to consider compounding legislation this spring. AVMA’s policies allow AVMA to advocate in D.C. on the Hill and with FDA, and it is likely that the compounding policies will ultimately serve as a basis for AVMA’s position on the legislation. If the AVMA does not communicate the needs of its members and their patients during these legislative discussions, then we lose an opportunity to shape that legislation. Keep in mind that the marketplace (i.e., the proportion of available FDA-approved drugs to commercially available compounds from bulk) could change if compounding legislation passes. Compounding, consistent with the Food and Drug Administration (FDA) Extra-Label Drug Use regulations, is the customized manipulation of an approved drug(s) by a veterinarian, or by a pharmacist upon the prescription of a veterinarian, to meet the needs of a particular patient. Currently, all compounding from bulk (unapproved, raw active ingredients) for animals is illegal per the FDA.
We are currently asking members to stay tuned, as we will be asking for their feedback on policy revisions shortly. Those will be available through NOAH on the AVMA website