Medicare Part D does not pay for API-based compounds. If CMS paid, someone made a mistake, opportunists exploited a loophole, and others did not catch it. The contemporary (non-medically necessary) compounding business model is based on marketing the spread, only instead of elevating wholesale AWP, they drop the bottom out of acquisition cost (purchasing API is much cheaper than purchasing FDA-approved finished drug products). If reimbursement is available under a payer model for experimental drugs/API-based compounds, then the model Dr. Woliner describes is indeed highly lucrative. And illegal?