Every manufactured prescription drug in the United States is traced hand to hand by federal law. Compounded medicine was left out by name. Custody is that chain: the pharmacy releases, the clinic receives and administers, the patient scans, and every line is signed by the hand that acted and chained to the one before it.

Custody is not a second artifact. The Seal stays the record and the Passport stays the proof. What changes is who may write to the record and who it can reach. Seven events, named plainly: released, shipped, received, administered, returned, recalled, reported. Every event on a unit carries the hash of the one before it, so a line cannot be tidied after the fact without the break showing.
Nothing changes at the bench. One code goes on the box, and the record fills itself from there.
01
The lot clears, the Evidence Passport is minted, the Seals print, exactly as today. The release slip that already goes in the box now carries a shipment code: one code for the box, one Seal per unit. Nothing new is typed, and nothing ships that was not released.
The shipment is written to the record as its first custody line, signed by the pharmacy, before the box leaves the building.

02
Every unit in the box lands on the clinic's desk with the pharmacy's paperwork attached, and the desk shows accept or hold with the reasons stated: paperwork on file, use-by clear, no recall recorded, the pharmacy on Veritura. A box that carries no Seal is typed in from the packing slip in thirty seconds, marked no record on file, and the ask goes to that pharmacy.
The desk costs the clinic nothing. No card, no agreement, and a pharmacy that has not sealed its box is visibly weaker on its own customer's screen.

03
The clinic scans the vial as it is drawn. The administration line is written: unit, lot, date, and the clinic's own reference. No patient name or chart ever enters Veritura, so no agreement is needed to start. The patient's phone shows the chain: released, received, administered, each with its date, and the clinic's name and nothing else.
The log a board asks a clinic to produce fills itself, one scan at a time.

04
The pharmacy declares once. Every clinic holding the lot sees the recalled units named on its desk and is emailed. Every patient who saved a unit is notified, directly and PHI-free. The pharmacy sees which clinics have opened the notice and which have not, so the follow-up call goes to the right desk.
An adverse event is filed from the unit's own record, with product, lot, pharmacy, and dates already in place. Patient identity stays with the clinic.

05
Every other figure a pharmacy holds is about what it made. Custody adds four about where it went: unaccounted, off path, expiring on a clinic shelf, and recall notices not yet opened. The same view 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. The full event record exports as CSV or JSON, so a pharmacy's own system can read it.

Where the patient’s contact lives
Two records, one join. The clinic’s administration line carries the unit, the lot, the date and the clinic’s own visit reference, and nothing else. A patient who scans the vial can save it to their own space with an email they type themselves. That email lives in the patient’s account, never in the clinic’s record, and Veritura never joins the two.
No name, chart or contact. The reference is yours, and Veritura never asks what it means. The log a board asks a clinic to produce is this line, per vial, per visit.
Scanning the vial and saving it creates the patient’s own space. The email is held there, for their notices, and is never written to the clinic’s or the pharmacy’s record.
Saved vials are reached through the patient’s own account. Everyone else is reached through the order list your clinic already holds. Nothing about a patient is stored to make the first path work.
What changes
A record with one author is a claim. A record with three is evidence.
Every clinic holding the lot, and every patient who saved a vial, in minutes.
Unaccounted, off path, expiring on a shelf, and notices not yet opened, by lot and by clinic.
The method
Documents arrive by email, upload, or API and are retained as received.
Read against identity anchors, your policy, and named public sources.
A named person signs every material decision, with the reason kept.
Cleared orders issue serialized Passports and Seals.
Every document and decision stays on the record for seven years.
Every hand writes in the same words, so a wholesaler, a board, or a rival can read a Veritura record without a key.
The pharmacy's two lines. The lot cleared, the Seals printed, and the box left under one shipment code.
The clinic's first line, written at the door with the accept or hold decision and its reasons.
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.
The lines that travel. A recall declared once reaches every desk holding the lot; a report is filed from the unit's own record.
The complete text, for the reader who wants the whole story before a call.
A record with one author is a claim. A record with three is evidence. Until Custody, a pharmacy published a record about a unit and hoped the patient saved it. Nobody wrote down who received the vial, whether it was still in date when it was drawn, or where it went if it was not. The regulators noticed this summer, and they said so in writing.
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.
The National Association of Boards of Pharmacy 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.
As of 31 May 2026 the agency had 990 adverse-event reports on compounded semaglutide and more than 730 on compounded tirzepatide. It reports fraudulent products whose labels name compounding pharmacies that do not exist, and counterfeit units found inside the legitimate supply chain.
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's guidelines on outsourcing sterile compounding tell a hospital pharmacy that buys from a 503B outsourcing facility to qualify the vendor and keep the records that show it did.
A clinic, medical spa, or telehealth practice opens On hand: every unit in the fridge by lot, with the pharmacy's paperwork behind it. Today shows 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.
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.
The clinic's reference is the clinic's own. No patient name or chart ever enters Veritura, so no agreement is needed to start.
An adverse-event report is drafted from the unit's record in the shape the national clearinghouse will expect, and the clinic sends it. The pharmacy learns that a report exists on one of its units. Patient identity stays with the clinic.
The Custody view sits under Prove and deliver. Every other figure a pharmacy holds is about what it made. These four are about where it went.
Units shipped and not yet received or returned, by lot and by clinic. The number a recall procedure assumes the pharmacy can state.
A Seal read at a clinic it was never shipped to, read twice, or read after it was administered. A fact about scans, stated as such, with the pharmacy told first. The words diverted, counterfeit, and stolen do not appear anywhere in the product; the pharmacy draws the conclusion.
Units received, not administered, inside fourteen days of use-by. The pharmacy warns the clinic before an inspector finds the vial.
Which clinics holding a recalled lot have not yet read the notice on their desk.
The same view issues a numbered custody statement per lot: released through administered, unaccounted stated, the chain verified, readable at a public address with no account. The full event record exports as CSV or JSON.
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.
Because no line in it is Veritura's. Each hand signs its own line. The lines are chained. Anyone can verify a statement without an account, and no record on file is a legitimate state the market learns to read. The event vocabulary and the export are published, so a wholesaler, a board, or a rival can read a Veritura record.
A buyer can put one sentence in 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.
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.
DSCSA: Federal Food, Drug, and Cosmetic Act section 581(13), definition of product. NABP: press release of 29 July 2026 on the adverse-event clearinghouse and model state language. FDA: concerns with unapproved GLP-1 drugs used for weight loss, page updated 1 September 2026. Texas: 22 Texas Administrative Code 291.133, pharmacies compounding sterile preparations. USP: General Chapter 797, quality assurance, recalls, complaints, and adverse-event reporting. Indiana: Senate Bill 282, 2026 session. Minnesota: HF 2779, 2026 session. ASHP: Guidelines on Outsourcing Sterile Compounding Services. The dated launch note with every citation is at /resources/custody.
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.

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. The administration line carries the unit, the lot, the date, and the clinic's own reference. The patient claims their own record by scanning the vial, and nothing about them is stored to make that work.
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.