Welcome back to this month’s edition of The Boesen & Snow Brief!

This month, we’re taking a closer look at what practitioners can actually prescribe as the peptide conversation evolves, what happens on the licensing side when a pharmacy changes hands, and we’re sharing our new white paper: a stage-by-stage guide to PBM audits.

Prescribing in the Gray Zone: Peptides, Compounding, and the Limits of State Prescriptive Authority

With so much attention on peptides and what pharmacies can compound, another question matters just as much: what can a practitioner actually prescribe?

Compounding is shaped by federal law and regulatory policy, while prescribing is governed by state law and the boards that license each practitioner. Regulators have not finalized any action since the July advisory committee votes, so nothing has changed about what pharmacies may lawfully compound.

Meanwhile, states are moving on their own, and discipline often turns on how a drug was prescribed and documented, not just the product itself.

Our article covers how we got here and five practical takeaways for prescribers.

Additional Articles:

Buying, Selling, and Pharmacy Change of Ownership: What Actually Happens on the Licensing Side

A change of ownership isn’t always one obvious event. A new investor, a new partner, or a quiet equity transfer higher up the ownership structure can trigger a reportable change in some states, even when nothing changes at the pharmacy itself.

Our Licensing Team explains what counts, why many states require notice or an application before a deal closes, and how to build licensing into your transaction timeline.

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Free White Paper: Navigating Pharmacy Audits

Understanding the PBM audit process early can make a meaningful difference for a pharmacy, and the first steps matter more than most people realize.

Our new white paper, Navigating Pharmacy Audits: A Stage-by-Stage Guide to PBM Audits, walks through all six stages, from the first notice to life after the final determination.

It covers what to do first, what can go wrong, and how a prepared pharmacy moves through the process differently.

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The BSL newsletter is provided for general informational purposes, does not constitute legal advice, and does not create an attorney-client relationship. The regulatory status of the matters discussed is current as of publication and is subject to change. This may be considered legal services marketing. Our ability to represent clients in a particular matter depends on that state's licensure and admission requirements, which may require pro hac vice admission or association with local counsel.