Key Takeaways Medspas and other entities operating in the aesthetic space that dispense or administer prescription drugs should assess whether they have obligations as dispensers under the DSCSA and ensure they have policies, procedures and controls in place to demonstrate compliance with applicable requirements. To avoid the deficiencies cited in the warning letter, dispensers should focus on strengthening supply chain controls, maintaining complete product records and ensuring operational readiness for FDA inspection. Dispensers that receive a Form FDA 483 documenting observations of potential violations after an FDA inspection should act immediately to develop a thorough response with supporting documentation. On April 1, 2026, the FDA issued a warning letter to Pure Indulgence Aesthetics (Pure Indulgence), a Texas-based medical spa. Notably, this is the first

Key Takeaways: The New York State Board of Pharmacy (NYBOP) issued guidance in December 2025 requiring licensure both for pharmacies and for each individual pharmacist participating in shared pharmacy services arrangements when servicing New York patients. Nonresident pharmacy registration alone is no longer sufficient to satisfy shared services compliance. While this requirement becomes effective May 22, 2026, organizations should not delay taking action now. A proactive assessment and timely remediation of any licensure gaps will be critical to ensuring compliance moving forward. What Organizations Should Be Doing Now Evaluate your shared services model to identify where operations may be impacted; Confirm that all pharmacists supporting or involved in New York operations, including remote personnel, hold appropriate licensure and identify any gaps; Implement proactive compliance measures for any