FDA Law Blog Points Out that Under the Current Definition of Dispensing a pharmacy's dispensing Controlled Substances (including compounded pain medications used via intrathecal pump, testosterone pellets etc.) to ANYONE other thanthe ultimate user patient or research subject is illegal!!! How many compounding pharmacists are guilty? Even if the Ensuring Safe Access to Prescription Medication Act of 2014 introduced by John Cornyn, a senator from the Compounding Capital of the World-Texas and Sherrod Brown, its passage would not protect those who have violated the law in the past from prosecution

And while I normally agree with the FDA Law Blog authors on this one, I think what is being overlooked is the compounding pharmacists role in this and how it would interplay with the DQSA and office use that is prohibited.  A detailed analysis needs to be done of The Ensuring Safe Access to Prescription Medication Act of 2014 before it is passed especially in light of all the current issues with compounding and compounded pain medications.

Legislation Would End “Constructive Transfer” and Change CSA Definition of “Dispense” to Permit Pharmacy Delivery of Controlled Substances to Physicians for In-Office Administration