Is a Compounded Drug Essentially a Copy? (503A)

Applies FDA's January 2018 "essentially a copy" tests for a section 503A compounded drug to the reader's answers.

Open the tool → Runs in your browser. Data leaves only if you deliberately send a problem report from the interactive tool.

Example

Same active ingredient as a commercial product
Yes
Commercial product status
Marketed, and not in shortage
Compounded strength
45
Commercial strength
50
Commercial product can be used by the route prescribed
Yes
Prescriber's significant-difference determination is documented
No
Prescriptions filled this month without a determination
2

Result: Essentially a copy under the guidance; prescription 3 of the month, within the four FDA's policy leaves alone.

The tool opens with these values already filled in. Replace them with your own.

What you enter

  • Same active ingredient as a commercial product (yes or no)
  • Commercial product status: marketed and not in shortage (marketed), on FDA's shortage list as currently in shortage (shortage), or discontinued (discontinued)
  • Compounded strength (same unit as the commercial strength)
  • Commercial strength
  • Commercial product can be used by the route prescribed (yes or no)
  • Prescriber's significant-difference determination is documented (yes or no)
  • Prescriptions filled this month without a determination
How this is calculated

Citation

FDA, Compounded Drug Products That Are Essentially Copies of a Commercially Available Drug Product Under Section 503A (guidance for industry, January 2018): strength within 10%, four or fewer prescriptions in a calendar month. A nonbinding enforcement policy. Read the source ↗

A reference and educational tool. Not medical, legal, or financial advice, and not a substitute for clinician judgment.

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Built by Clay Good. Source on GitHub.