Manufactured prescription drugs are traced hand to hand. Compounded medicine never was.
The federal tracing law excludes drugs compounded under 503A or 503B by definition. Custody gives each unit one record, from the pharmacy's release to the patient's phone.
Drug Supply Chain Security ActFD&C Act §581(13)
… a drug compounded in compliance with section 503A or 503B.
NABPJuly 29, 2026
… the absence of supply-chain traceability tools for compounded products, and the difficulty of verifying the bulk substances from which compounded medications are made …
Five moves
From the release slip to the chair, in five moves.
Nothing changes at the bench. Each event carries the hash of the one before it, so a line cannot be tidied after the fact.
The release slip carries the codeOne code for the box, one Seal per unit. Nothing new is typed.
The lot clears, the Evidence Passport is minted, the Seals print.
The shipment is written to the record, signed by the pharmacy, before the box leaves the building.
The slip that already goes in the box now carries the code.
The box lands on the clinic’s deskThe clinic scans the slip: accept or hold, with the reasons stated.
Paperwork on file, use-by clear, no recall recorded, the pharmacy on Veritura.
Typed in from the packing slip, marked no record on file, and the ask goes to that pharmacy.
The desk is the clinic's view of every unit on hand. No card, no agreement, for a clinic, medical spa or telehealth practice.
One scan at the chairThe administration line: unit, lot, date and the clinic's own reference.
No patient name, chart or prescription ever enters Veritura.
The log a board asks a clinic to produce, one scan at a time.
Released, received, administered, each dated, with the clinic's name and nothing else.
Declare a recall onceEvery desk holding the lot sees it, and who has opened the notice.
Every clinic holding the lot sees the recalled units named on its desk.
Every patient who saved one is notified directly, PHI-free.
The pharmacy sees which clinics have opened the notice, so the follow-up call goes to the right desk.
Four numbers and a public statementUnaccounted, off path, expiring on a shelf, notices not yet opened.
Every other figure a pharmacy holds is about what it made. These four are about where it went.
Released through administered, unaccounted stated, the chain verified, public with no account.
The full event record, so a pharmacy's own system can read it.
Three hands
One author is a claim. Three authors are evidence.
Each hand signs its own line. No line is Veritura's.
Releases the lot and ships it, one shipment code per box, one Seal per unit.
Receives at the door and administers at the chair, on a desk that costs it nothing.
Scans the unit and sees released, received and administered, each dated, with the clinic's name.
One record
Seven events, one vocabulary.
The pharmacy writes two lines, the clinic writes two, and the lines that travel reach every desk holding the lot.
The lot cleared, the Seals printed, and the box left under one shipment code.
Written at the door, with the accept or hold decision and its reasons.
One scan at the chair, or one scan to send a unit back.
A recall declared once reaches every desk holding the lot.
Where the patient’s contact lives
No name enters the clinic’s record.
A patient who wants to be reached saves the unit themselves, with an email they type. The unit is the only join, and Veritura never joins the two records.
A scan that does not fit is a fact. It is never an accusation.
Off path, one of the four numbers, means a scan that does not fit the unit’s record. There are four cases.
The shipment named one clinic and a different one scanned it.
One serial carries two administration lines, each dated.
The unit never passed the clinic's door decision on the record.
A unit sent back to the pharmacy was scanned again.
Custody never uses the words diverted, counterfeit or stolen. The pharmacy is told first, and draws the conclusion.
The full detail.
The clinic's desk, the four numbers, how the chain holds, and the public record behind it.
The dated launch note, with every citationSeven events, one vocabulary 7 events
- Released and shipped
- The pharmacy's two lines. The lot cleared, the Seals printed, and the box left under one shipment code.
- Received
- The clinic's first line, written at the door with the accept or hold decision and its reasons.
- Administered and returned
- The clinic's second line. One scan at the chair, or one scan to send a unit back, each with the clinic's own reference.
- Recalled and reported
- The lines that travel. A recall declared once reaches every desk holding the lot; a report is filed from the unit's own record.
- One vocabulary
- Every hand writes in the same words, so a wholesaler, a board, or a rival can read a Veritura record without a key.
The clinic's desk, for nothing
- On hand
- A clinic, medical spa, or telehealth practice sees every unit in the fridge by lot, with the pharmacy's paperwork behind it.
- Today, in four stacks
- Arrived and awaiting a decision, expiring within fourteen days, recalled and not yet read, and waiting on paperwork. The desk takes every shipment, sealed or not.
- The door decision
- Paperwork on file or not, use-by clear or not, a recall reported or not, the pharmacy on Veritura or not. A box that carries no Seal is typed in from the packing slip, marked no record on file, and the ask goes to that pharmacy in the clinic's name.
- Administration
- One scan per unit. The clinic's reference is the clinic's own. No patient name, chart or prescription ever enters Veritura, so the clinic starts without sending any patient detail.
- The report
- An adverse-event report is drafted from the unit's record, with the product, lot, pharmacy and dates in place, and the clinic sends it. The pharmacy learns that a report exists on one of its units. Patient identity stays with the clinic.
- What it costs
- Nothing. A pharmacy that has not sealed its box is visibly weaker on its own customer's screen.
The four numbers, and the statement
- Unaccounted
- Units shipped and not yet received or returned, by lot and by clinic. The number a recall procedure assumes the pharmacy can state.
- Off path
- A unit read at a clinic it was not shipped to, administered twice, administered before any receipt, or read after it was returned. A fact about scans, stated as such, with the pharmacy told first.
- Expiring on a clinic shelf
- Units received, not administered, inside fourteen days of use-by. The pharmacy warns the clinic before an inspector finds the unit.
- Recall notices not yet opened
- Which clinics holding a recalled lot have not yet read the notice on their desk.
- The statement
- The Custody view, under Prove and deliver, issues a numbered custody statement per lot: released through administered, unaccounted stated, the chain verified, readable at a public address with no account. It is what a board asks for under a recall procedure, and what a buyer's contract can ask for by name.
How the chain holds
- Each line, chained
- Each custody line is attributed to the account that acted and hashed into a chain with the line before it, so a renamed actor or a deleted middle line breaks verification. The statement says on its face whether an independent checkpoint was retained.
- No line is Veritura's
- Each hand signs its own line. Anyone can verify a statement without an account, and no record on file is a legitimate state the market learns to read.
- Published
- The event vocabulary and the export are published, so a wholesaler, a board, or a rival can read a Veritura record without a key.
- One sentence for a supplier agreement
- For each lot delivered, a certificate of analysis and a custody record the buyer can verify without an account, stating units released, received, and unaccounted.
- On the unit's page
- The same code the patient already scans now carries the middle hand: received by the clinic, with the date, and administered, with the date. The clinic's brand name and nothing else. No score, no posture word, no patient.
The public record this page stands on 6 sources
- Drug Supply Chain Security Act, section 581(13)
- The federal definition of a traceable product excludes a drug compounded in compliance with section 503A or 503B. Every manufactured prescription drug carries a serialized package and a transaction record that passes from hand to hand. Compounded medicine carries neither, by statute.
- NABP, 29 July 2026
- Named the gaps it will now build standards around, in its own words: the absence of supply-chain traceability tools for compounded products, and the difficulty of verifying the bulk substances from which compounded medications are made. It is also building a national adverse-event clearinghouse for compounded medicine.
- 22 Texas Administrative Code 291.133
- A pharmacy compounding sterile preparations must hold a written procedure for preparation recall. USP General Chapter 797 carries the same requirement, alongside complaint handling and adverse-event reporting. Both assume the pharmacy can say who received a lot.
- Indiana Senate Bill 282
- Registers medical spas with the state from 1 January 2027 and writes the bulk-substance rules for the compounded preparations they administer into the statute.
- Minnesota HF 2779
- Requires compounded medicine administered in a clinic to come from a licensed pharmacy with a patient-specific justification on file.
- ASHP, Guidelines on Outsourcing Sterile Compounding Services
- Tell a hospital pharmacy that buys from a 503B outsourcing facility to qualify the vendor and keep the records that show it did.
What it does not do
- The medicine
- Custody says who held a unit and what the paperwork established. It never tests, grades, or endorses the medicine, and it is not a certificate of analysis.
- Off path
- A fact about where and when a Seal was read. The pharmacy draws the conclusion.
- Patient identity
- No patient identity is stored in the clinic’s or the pharmacy’s record; a patient who saves a unit holds their own contact in their own account, and claims their own record by scanning.
- What it replaces
- Nothing shipped is retired. Custody is the roof over the Passport, the Seal, the order channels, the recall net, and the two agents.
Custody says who held a unit and what the paperwork established. It never tests, grades, or endorses the medicine, and it is not a certificate of analysis.
Questions, answered plainly.
No. The clinic, medical spa, or telehealth desk is free: no card, no agreement, nothing to buy. The pharmacy's Custody view is part of its workspace.
No patient name, chart or prescription. The administration line carries the unit, the lot, the date, and the clinic's own reference. A patient who wants to be reached saves the unit with an email they type themselves, kept in their own account until they delete it, and never written to the clinic's or the pharmacy's record.
It still lands on the desk. The clinic types it in from the packing slip, the units are marked no record on file, and the ask for the paperwork goes to that pharmacy in the clinic's name.
Still have questions? Talk to a person.
Keep reading.
The statutes and regulator statements behind the chain, dated and cited.
The serialized code on every unit that Custody writes to.
How a passport is issued, what it binds, and what a patient sees.