Updated September 2026
Short answer: Under federal law, office use compounding comes from 503B outsourcing facilities. FDA reads section 503A as requiring a prescription for an identified patient, and its guidance points clinics that want non-patient-specific stock to 503B facilities. State law is a second layer: in our research, 17 jurisdictions still allow some 503A office use, 23 do not, and 11 are unclear. The trend is toward closing it, with rule changes or board notices in Florida, Oregon, Vermont, Nevada and California since 2025.
Office use compounding under federal law
A 503A pharmacy (or physician) compounds for an identified patient on a valid prescription, or in limited anticipatory batches based on its own prescription history, which FDA limits to a 30-day supply. A 503B outsourcing facility registers with FDA, compounds under CGMP, is inspected on a risk-based schedule, reports adverse events, and may supply non-patient-specific product to clinics for office use. FDA's 503A prescription-requirement guidance directs practices wanting office stock to 503B facilities.
Two federal points catch clinics out:
- State permission doesn't change the federal rule. The Texas State Board of Pharmacy notes that office-use distribution allowed under Texas law "may not be allowed by federal law."
- 503B product can't be resold. Under section 503B(a)(8), only the outsourcing facility may sell its product. FDA's 2023 draft guidance says it should go from the facility to the entity that administers or dispenses it, so clinic-to-clinic resale is the core concern.
For how ordering works in each lane, see 503A or 503B? Ordering compounded medications the compliant way.
503A office use by state: what changed in 2025–2026
Florida (August 3, 2026)
Florida's compounding rule, 64B16-27.700, was amended three times between April 2025 and August 2026. It now sets out office-use supply only for veterinarians. For human drugs, "office stock or office use" compounding must strictly follow federal law, including sections 503A and 503B. Florida sources that predate 2025 may describe different terms.
Oregon (June 17, 2026)
Oregon's new Division 183 rules define compounding around a patient-specific prescription. Anyone compounding drugs distributed in Oregon without one must register as a Manufacturer.
Vermont (February 1, 2026)
Vermont's rewritten pharmacy rules allow human compounding only on a patient-specific order, or in limited quantities for a specific patient. They apply to any pharmacy dispensing to people in Vermont.
Nevada (June 2025)
In a June 2, 2025 notice, the Nevada Board of Pharmacy reminded 503A pharmacies that "they are not permitted to sell compounded medications to practitioners." Nevada law lets practitioners buy compounded drugs directly from outsourcing facilities instead.
California (October 2025)
California's statute still lets a pharmacist furnish a "reasonable quantity" of compounded drug to a prescriber for office use. But the rules that defined that quantity were repealed when new compounding regulations took effect October 1, 2025, and the new rules treat compounding as patient-specific. The Board's current reading was not confirmed.
Michigan: office use by authorization
MCL 333.17748b bars compounding for a prescriber to administer without a prescription unless LARA authorizes the pharmacy, for a named prescriber or facility, in limited quantities, for two years. Topical non-sterile compounding is exempt. LARA's public list names two authorized pharmacies.
North Dakota: in-state only
North Dakota allows compounded human drugs for office administration only from a North Dakota-licensed outsourcing facility or a pharmacy located in the state. Out-of-state 503A pharmacies may not supply office stock.
Where limited 503A office use remains
State law still allows some 503A office use in Alabama, Arizona, Connecticut (non-sterile, up to 30 days), Illinois (non-sterile only), Kansas, Nebraska, New Hampshire, North Carolina, Oklahoma (in-state pharmacies), South Carolina, Tennessee, Texas, Virginia (critical emergency need) and Washington. Common conditions: administration in the office only, no resale or dispensing, an office-use label, and sometimes a written agreement or a requirement that the product isn't commercially available.
503B office use: state licences for outsourcing facilities
Buying from a 503B doesn't end the diligence. In our research, 41 jurisdictions require an out-of-state outsourcing facility to hold a state licence or registration before shipping in, as an outsourcing facility, manufacturer, wholesaler or pharmacy. In Connecticut, Florida, Hawaii, Pennsylvania and Texas it depends on the product or distribution type, and Indiana, Louisiana, Montana, Nebraska and Wisconsin were not confirmed. Start with FDA's registered outsourcing facility list, then check the licence for your state.
Office use compounding by state: all 51 jurisdictions
The last column shows whether an out-of-state 503B needs a state licence to ship in. Summaries are current as of September 2026. Full citations are in the 503A office-use map and the 503B licensing map.
| State | 503A office use | Conditions or notes | Out-of-state 503B licence |
|---|---|---|---|
| Alabama | Allowed with limits | Written order, "For Office Use" label, administer only | Yes |
| Alaska | Not confirmed — check with the board | — | Yes |
| Arizona | Allowed with limits | Administer to the practitioner's own patients; no resale | Yes |
| Arkansas | Not allowed | Human office stock comes from Arkansas-permitted 503Bs | Yes |
| California | Allowed with limits | Statute allows it; Oct. 2025 rules are patient-specific, so limits are unclear | Yes |
| Colorado | Not allowed | Veterinary office stock only | Yes |
| Connecticut | Allowed with limits | Non-sterile up to 30 days; sterile needs a manufacturer registration | Depends |
| Delaware | Not confirmed — check with the board | — | Yes |
| District of Columbia | Not confirmed — check with the board | — | Yes |
| Florida | Not allowed | Rule defers to federal law (amended Aug. 3, 2026) | Depends |
| Georgia | Not allowed | Board rule prohibits it; 503B supplies office use | Yes |
| Hawaii | Not confirmed — check with the board | — | Depends |
| Idaho | Not confirmed — check with the board | "Minimal quantities" rule does not say if it covers compounds | Yes |
| Illinois | Allowed with limits | Non-sterile only; sterile office use only from licensed 503Bs | Yes |
| Indiana | Not confirmed — check with the board | — | Not confirmed |
| Iowa | Not confirmed — check with the board | — | Yes |
| Kansas | Allowed with limits | Limited quantities, labeled "For Office Use Only – Not For Resale" | Yes |
| Kentucky | Not allowed | Compounding tied to a prescription or patient-specific order | Yes |
| Louisiana | Not allowed | Veterinary office use only | Not confirmed |
| Maine | Not allowed | Veterinary office use only | Yes |
| Maryland | Not allowed | Sterile office stock from FDA-registered facilities with a Maryland permit | Yes |
| Massachusetts | Not allowed | Patient-specific prescription required; office stock from 503Bs | Yes |
| Michigan | Allowed with limits | Needs a LARA authorization for a named prescriber; topical non-sterile exempt | Yes |
| Minnesota | Not allowed | Identified patient and prescription required | Yes |
| Mississippi | Not allowed | Patient-specific compounds may be administered in the office | Yes |
| Missouri | Not allowed | Only a Missouri-licensed 503B "drug outsourcer" may supply office use | Yes |
| Montana | Not confirmed — check with the board | A pending rule would make all compounding patient-specific | Not confirmed |
| Nebraska | Allowed with limits | "For office use only and not for resale" | Not confirmed |
| Nevada | Not allowed | Board notice (June 2025); buy office stock from outsourcing facilities | Yes |
| New Hampshire | Allowed with limits | Limited quantities; not commercially available; no resale | Yes |
| New Jersey | Not allowed | Patient-specific prescription required except as federal law permits | Yes |
| New Mexico | Not allowed | Veterinary office use only | Yes |
| New York | Not allowed | Office stock from a New York-registered outsourcing facility | Yes |
| North Carolina | Allowed with limits | Must comply with federal law; no resale | Yes |
| North Dakota | Allowed with limits | Only from ND-licensed outsourcing facilities or in-state pharmacies | Yes |
| Ohio | Not allowed | Patient-specific only; out-of-state non-patient-specific shipments barred | Yes |
| Oklahoma | Allowed with limits | In-state pharmacies with a Drug Supplier Permit (5% cap) | Yes |
| Oregon | Not allowed | Rules effective June 17, 2026; non-patient-specific needs Manufacturer registration | Yes |
| Pennsylvania | Not allowed | Rule requires compliance with federal 503A | Depends |
| Rhode Island | Not allowed | Prescription required; only outsourcing facilities exempt | Yes |
| South Carolina | Allowed with limits | Physicians may keep and administer; no resale | Yes |
| South Dakota | Not confirmed — check with the board | — | Yes |
| Tennessee | Allowed with limits | Not commercially available; on the prescriber's order | Yes |
| Texas | Allowed with limits | Written agreement and labeling; Board notes federal law may not allow it | Depends |
| Utah | Not allowed | Regulators say a 503B is required | Yes |
| Vermont | Not allowed | Rules effective Feb. 1, 2026; patient-specific only | Yes |
| Virginia | Allowed with limits | Critical emergency need, or as federal law allows | Yes |
| Washington | Allowed with limits | Administer in the practice; no resale | Yes |
| West Virginia | Not confirmed — check with the board | Only a general 5% transfer cap found | Yes |
| Wisconsin | Not confirmed — check with the board | — | Not confirmed |
| Wyoming | Not allowed | An "office use" order is not a valid prescription | Yes |
Before you stock compounded preparations
- Know which lane the seller is in. Check 503B status on FDA's list.
- If you're relying on 503A office use, confirm your state allows it and that it survives the federal rule.
- Confirm the 503B holds your state's licence.
- Keep office stock for administration in your practice. Don't resell or transfer 503B product to another clinic.
MedGrid lists 503B office-use products, and vendor licences appear on product pages, marked verified by MedGrid. For patient-specific 503A prescriptions, the doctor portal routes orders to pharmacies licensed for the patient's state. Browse pharmacies and outsourcing facilities.
Frequently asked questions
What is office use compounding?
Office use compounding means a pharmacy supplies compounded preparations to a practice without a prescription for a named patient, so the practice can administer them in the office. FDA's position is that 503A pharmacies need patient-specific prescriptions, so non-patient-specific office stock comes from 503B outsourcing facilities.
Can a 503A pharmacy sell office stock to my clinic?
Federally, FDA says 503A compounding needs a prescription for an identified patient. Some states still allow limited 503A office use under state law, including Texas, Kansas and Illinois (non-sterile only), but federal law still applies. Florida, Oregon, Vermont and Nevada have moved away from it since 2025.
Where can clinics get compounded office stock?
From an FDA-registered 503B outsourcing facility, which may supply non-patient-specific product for office use. Check that the facility is on FDA's registered list and holds any licence your state requires.
Do 503B outsourcing facilities need a state licence?
In most states, yes. In our research, 41 jurisdictions require an out-of-state 503B to hold a state licence or registration before shipping in. Five states depend on the product or distribution type, and five were not confirmed.
Can I resell 503B product to another clinic?
No. Under section 503B(a)(8), only the outsourcing facility may sell or transfer its compounded drugs. FDA's 2023 draft guidance says product should go from the facility to the entity that administers or dispenses it.
This article is general information, not legal advice. Compounding rules change often; confirm with your state board of pharmacy or a healthcare attorney before ordering office stock.
Check your state, then source office stock with the paperwork in view. Open the sourced office-use compounding map on MedGrid, or verify your NPI and see wholesale pricing.
Sources
- Prescription Requirement Under Section 503A of the FD&C Act – Guidance for Industry, FDA/CDER (2016-12-01)
- Registered Outsourcing Facilities, FDA (2026-09-08)
- Prohibition on Wholesaling Under Section 503B of the FD&C Act – Draft Guidance for Industry, FDA/CDER (2023-06-27)
- Rule 64B16-27.700 Compounding (effective 8/3/2026), Florida Department of State – Florida Administrative Code (2026-08-03)
- Notice of FDA's Declaratory Orders Resolving Shortages of Tirzepatide and Semaglutide Injection Products, Nevada State Board of Pharmacy (2025-06-02)
- Administrative Rules for the Vermont Board of Pharmacy (effective February 1, 2026), Vermont Office of Professional Regulation (2026-02-01)
- OAR 855-183 – Drug Compounding (effective 06/17/2026), Oregon Secretary of State (2026-06-17)
- Cal. Bus. & Prof. Code §4052, California Legislative Information (2026-01-01)
- MCL 333.17748b, Michigan Legislature (2014-09-30)
- N.D. Admin. Code 61-02-01-03 – Pharmaceutical compounding standards, North Dakota Legislative Branch (2024-01-01)
- TSBP Rules – Frequently Asked Questions (office use), Texas State Board of Pharmacy (2025-02-07)
