Collecting this in one place because it comes up every few weeks and the answer is always assembled from scratch. It is about compounded supply, and it is deliberately narrow — everything I am not confident about is marked as such.
What is actually established
They are two different exemptions from the same federal requirements and they buy different things. A 503A pharmacy is regulated primarily by the state board, needs a patient-specific prescription, is exempt from CGMP, and may use a bulk substance that has a USP monograph, is a component of an approved drug, or appears on the 503A bulks list — three independent doorways. A 503B outsourcing facility registers with the FDA, is inspected on a risk basis, must comply with CGMP, may compound for office stock without a patient-specific prescription, and has one doorway to a permitted bulk substance: the 503B bulks list, or the drug shortage list.
The condition it depends on
The enforcement dates were staggered by category — 503A first, 503B a few weeks later — because outsourcing facilities have manufactured inventory and clinic contracts to unwind while a 503A makes to order.
The practical version
Two things anyone can check: a state licence number for a 503A, and an FDA outsourcing-facility registration for a 503B. Both are publicly searchable, and a pharmacy unwilling to give you either has answered the question.
What I am not sure about
What I am after is why a shortage listing created a legal pathway at all, since a shortage is a supply fact rather than a permission. Tell me what I have not thought of.
— LarryQC_SD · corrections welcome and will be edited into this post with credit