The short version. An established med spa wanted to add peptides and NAD+ alongside its aesthetic menu. The
clinical work was the small part. The larger part was sourcing that could be defended and a
website that stopped making claims the products cannot support.
What this is. A real MDside engagement, described without naming the client. No client name, location, ownership or commercial terms appear here, and nothing below identifies the practice. It is not a client case study and it is not a testimonial: the client has not endorsed us and is not quoted. The regulatory points are cited at the foot of the page.
Why peptides are not just another injectable
A neurotoxin has an approved label. Much of what is marketed as peptide therapy does not, and the regulatory question is not whether a provider may prescribe off-label — they may — but whether the specific substance can lawfully be compounded and obtained at all.
FDA signalled removing a number of peptides, BPC-157 among them, from Category 2. That is not the same as adding them to the list a pharmacy may compound from. Treating a signal as permission is the most common error we see on this menu.
What had to be decided before anything was offered
- Sourcing, per product. Which pharmacy, under which authority, and whether the substance may lawfully be compounded at all. Research-grade material is not a supply chain.
- An ordering provider and protocol for each addition, including NAD+, which needs an infusion rate specified and documented sourcing.
- Who may administer what, written against the delegation rules of the state the practice operates in rather than a template from another one.
- What the practice would decline to offer. The menu discipline is the compliance strategy; a director who never says no is not providing oversight.
The website was the biggest change
Most of the remediation was copy. Anti-ageing, longevity and recovery claims attach easily to peptides and NAD+ and are exactly the claims that create exposure, because they are therapeutic claims about products with no approval to support them.
FDA approved, cleared, registered and compounded mean four different things, and marketing pages routinely use them interchangeably. Rewriting that language is unglamorous and it is the single highest-yield thing a practice adding these services can do.
What we would tell the next practice
- Decide sourcing before you decide pricing. If it cannot be obtained lawfully, nothing else matters.
- Write the protocol per product, not per category.
- Audit the website the same week the service goes live, not months later.
- Keep a list of what you declined and why. It is the best evidence that oversight is real.
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Frequently asked questions
Can a med spa legally offer peptide therapy?
It depends entirely on the specific peptide and how it is obtained. Some can be compounded lawfully and some cannot, and an FDA signal about category placement is not authorisation.
What makes NAD+ different from a vitamin drip?
It needs a provider order, a protocol specifying infusion rate, and documented sourcing. The marketing claims around it also attract more attention than a hydration bag does.
Is off-label prescribing the problem?
No. Off-label prescribing is lawful medical practice. The problems are supply — whether the substance may be compounded at all — and advertising a therapeutic benefit the product is not approved to claim.
Sources. FDA category placement of peptides including BPC-157; the distinction between FDA approved, cleared, registered and compounded; NAD+ ordering and protocol requirements. Engagement details are generalised and no client is identified.
General information, not legal advice. This page describes a real engagement without identifying the client. Confirm your own position with healthcare counsel licensed where you operate.