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In response, CMS has proposed a reinterpretation of the statutory exclusion, distinguishing between drugs used for weight loss and those used for the treatment of obesity. This shift would allow Part D and state Medicaid coverage for anti-obesity medications (AOMs) prescribed specifically for obesity

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Take that dose away, and the mimicry stops

The shortage-based legal exemption that underpinned widespread compounded semaglutide availability is no longer active for either 503A pharmacies or 503B outsourcing facilities Compounded GLP-1 programs operating today must navigate a legal framework that includes restrictions on compounding drugs that are commercially available drugs - meaning the compounding pharmacy's specific formulation, documentation, and prescriber individualization process matters for legal compliance The FDA still permits compounding under 503A for individual patient-specific prescriptions that involve a prescriber-documented "significant difference" from the commercially available product - but that requires specific clinical justification, not just a standard intake form Availability of specific compounded GLP-1 formulations may be affected by FDA enforcement actions, pharmacy-specific compliance status, and ongoing regulatory developments in this space None of this means compounded GLP-1 programs are operating illegally

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