Monday, November 25, 2013

FACT: Very few people are experts on the DQSA at this stage. Just because an attorney or even a non attorney for that matter does a presentation, speech, CLE, CE etc. on compounding pharmacy law, the DQSA, criminal federal or state law as it relates to compounding pharmacies does not mean that person speaking is an expert on the topic.

Be very careful in this area.  Do your own research, research the speakers but also research the topic.  Listen careful to what the speaker says. Are speakers merely stating an opinion of what they believe the DQSA means.  Of what they wish it meant? Are they telling you what they don't know along with what they do know.  Are they relying on congressional intent and the actual language of the statute? They should be at this point.  Please remember, however, that the FDA is task with producing regulations as they relate to the DQSA.  Some areas of the answers to specific questions that relate to the DQSA won't be known until these regulations are officials.  You can't believe everything people tells you when it comes to the DQSA or other areas of compounding law. Check it out for yourself.

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