The ACP Just Called for Supplement Reform. Fullscript has Already Built It.

In July 2026, the American College of Physicians the nation's second-largest physician group, representing 163,000+ physicians published a position paper in Annals of Internal Medicine with a blunt warning – roughly 100,000 supplement products sit on the U.S. market, many adulterated or unproven, and physicians lack the tools to navigate them safely.

The paper lays out several priorities for protecting patients. Headlines from critics will read "anti-supplement", but when you look closer at the ACP's core concerns, quality, adulteration, lack of evidence-based guidance, and no clinician oversight are exactly what a quality-first, practitioner-guided model was designed to solve. These are systemic reforms that will take years, possibly decades, to legislate. Fullscript already operationalizes all four.

Here's what the paper says, where I agree, and what we're doing about it here at Fullscript.

The ACP is right: The supplement industry has a quality problem

There is a problem with the supplement industry, and it needs higher standards to prevent fake and unsafe products from reaching the market. When a 2022 JAMA audit of 30 immune health products sold on Amazon finds that 17 had inaccurate labels, 13 were misbranded, and 9 contained ingredients not listed on the label, that is not a fringe issue. In recent years, they’ve claimed to beef up their quality control practices, yet problems still continue to be reported. That is a systemic failure on the world's largest retail platform.

The high count of adulterated and mislabeled supplements erodes trust. It makes providers and patients skeptical of all supplements, even though when sourced, stored, and dosed appropriately, supplements can be a meaningful part of supporting health. The bad actors are impacting the reputation of an entire industry, and current regulations are allowing them to thrive in a market already flooded with misinformation.

That is the structural failure: a regulatory gap that permits bad actors, and a marketplace that offers no reliable signal of quality to the provider trying to make a recommendation. 

And providers are making that call constantly: in a January 2026 Sermo survey of 374 U.S. physicians, 94% said a patient had purchased a supplement specifically because they recommended it, and 76% said most or nearly all of their patients follow their guidance. Yet 82% of those same physicians said they hesitate to recommend a product because it lacks scientific backing, and the majority cited unclear labeling and overstated marketing claims. Patients are already outsourcing this decision to their provider. The provider just doesn't have the tools to make it safely.

What the ACP's priorities actually call for

The ACP's position paper outlines several recommendations for change in the supplement industry, 6 of which caught my attention:

• Remove adulterated products and get unsafe, mislabeled supplements off shelves
• Strengthen FDA oversight by mandating premarket approval and enabling mandatory recalls
• Improve provider–patient communication by creating ongoing dialogue about safe supplement use
• Expand nutrition knowledge by equipping providers with more clinical resources
• Ensure science-based consumer information with vetted, referenced resources

These are the right priorities. The question is: do providers have to wait for Congress to act before they can practice safely in this space?

Priority 1: Adulteration 

The ACP's central alarm is about what's in the products patients are taking. It is also Fullscript's clearest differentiator.

Instead of waiting for post-market recalls, the only enforcement mechanism under the 1994 Dietary Supplement Health and Education Act (DSHEA), Fullscript makes quality a precondition of listing.

Third-party cGMP certification 

Before a product reaches the Fullscript catalog, its brand and contract manufacturer must verify third-party cGMP certification. This is a standard they must prove annually, not just at onboarding.

Fullscript maintains direct, 1:1 relationships with every brand partner. This eliminates the intermediaries where adulteration and quality failures most commonly enter, a gap the ACP paper identifies as increasingly dangerous given "the expansion of online commerce and increasing complexity of global supply chains."

Clinical-team vetting

New brands pass an in-depth quality-control documentation review assessed by Fullscript's medical team before a single product is added. 

As of March 2026, New Brands and SKUs now need to provide:

• Completed certificates of analysis measuring both potency and purity
• Images of product labels for review by medical and quality teams
• Stability documents to ensure the product meets the expiration date claim

Ongoing blind testing 

Products are pulled directly off warehouse shelves (not supplied by the brand) and sent to independent labs for potency, purity, and contaminant screening (heavy metals, bacteria, pesticides). Brands cannot pay or influence when or if their products will be tested while consenting to ongoing blind testing. Fullscript has full control of which products from the catalog get tested.

Fullscript invests $8,000,000 annually in this program. The result: providers don't have to police the 100,000 SKUs in the market. That work is already done at the catalog level with over 350 brands and 15,000 products available on Fullscript.

When testing catches a failure

This is not theoretical. In our quarterly blind testing program, a top-selling B12 product from a major brand failed potency testing. Fullscript immediately delisted it. We coordinated directly with the brand, which drove a full reformulation. The product returned to the catalog only after the reformulated version passed independent purity and potency testing.

No patient was harmed. No recall was necessary. The system caught it before it reached them.

That is what continuous surveillance looks like, and it is fundamentally different from a one-time regulatory gate. FDA premarket approval, if enacted, would be a single checkpoint. Fullscript's model provides ongoing verification that what's in the catalog still meets the standard it met during initial approval.

Priority 2: FDA oversight 

The debate over premarket approval has real trade-offs on both sides, and Fullscript doesn't need to pick one to make its point: whatever bar Congress sets, a one-time approval isn't the same as an ongoing one.

That distinction matters more than it sounds. "FDA approved" is a powerful signal to a patient or a provider, but it describes a moment, not a guarantee. It tells you a formulation cleared review once, submitted by a specific manufacturer at a specific facility. It doesn't tell you whether that facility, that supplier, or that formulation is still meeting the standard two years later. 

Fullscript cannot legislate. But it functions as an additional oversight layer today, while regulatory reform including the Dietary Supplement Listing Act of 2026 works through Congress. Brand vetting, annual cGMP verification, and ongoing surveillance testing managed by an in-house clinical team are mechanisms that complement stronger FDA authority rather than competing with it.

Premarket approval would add another gate. Continuous independent review ensures that gate holds over time. Providers need both and they have one of them now.

Priority 3: Improving provider–patient communication

The ACP calls for better provider–patient communication about supplements. I know exactly what they're describing because I lived the opposite for years.

Early in my practice, the supplement recommendation process was simple: I'd write down a list of products on a notepad and hand it to the patient. What happened next was entirely up to them. They might find the product at a health food store or search for it online. They might get a product that didn't contain the correct therapeutic dose or in some cases do nothing at all, because the process wasn't seamless enough to sustain adherence.

That notepad was a dead end. The moment the patient walked out of my office, I lost all visibility into whether they followed through, what they actually purchased, and whether they were ultimately ending up with a safe product at the right dose.

Fullscript replaces that dead end:

• Supplement plans patients access through their Fullscript accounts with specific products, specific doses, and instructions
• Medically-reviewed handouts and resources practitioners can attach to each recommendation, so their patients understand what they are taking and why
• Adherence tools with automated reminders and auto refill options that sustain the plan after the patient leaves the office
• Currently-taking features that give providers visibility into what their patients are actually using, including products from other sources

This is precisely the ongoing, risk-based dialogue the ACP calls for. It is communication digitized, documented, and made persistent with over 125,000 providers already using it.

Priority 4: Closing the knowledge gap

I got what seemed like minutes of supplement education in medical school and residency. That experience is not unusual, it is often the case for conventionally trained providers.

The result is a knowledge asymmetry that plays out in exam rooms daily: a patient arrives with hours of podcast-fueled research about a specific supplement, and the provider across from them doesn't feel equipped to evaluate the claim, let alone make a recommendation. What do most doctors do? They defer to the internet, to AI tools, or to third-party sources that may be no more reliable than what the patient already found.

The irony is sharp: the provider becomes another node pointing patients back to the same unvetted ecosystem the ACP is warning about.

Closing the gap with Fullscript Academy

Staying current with the latest in healthcare shouldn't disrupt a provider's workflow. Fullscript Academy distills the latest research into expert-led education that providers can put into practice immediately — whether they need a five-minute refresh on a specific supplement or a deep-dive bootcamp on nutrition or whole person care.

Adding an additional layer of confidence with Fullscript Assist

Education alone doesn't help in the moment when a patient is sitting across from you and you need to act now. That is what Fullscript Assist was built for.

Fullscript Assist is a HIPAA-compliant clinical decision support AI, purpose-built for integrative healthcare, citation-backed, and grounded in an evidence framework built by clinicians for clinicians. It helps draft personalized care plans that embed nutrition and lifestyle guidance alongside supplement suggestions surfacing clinical considerations and safety flags while keeping the provider in full control of every decision.

It can take into account patient context: supplements the patient is currently taking, medications, conditions, lab results, and wearable data which can all be considered before a recommendation is drafted. When a patient on warfarin asks about fish oil, Assist does not simply flag a binary interaction. It highlights the potential negative interactions, suggests alternatives or dose adjustments, and considers the full context of the patient's plan for clinical review. It is not a lookup table. It is a red flag plus a reroute with the provider making the calls.

Fullscript does not just call for better nutrition knowledge. It delivers it translating research into personalized, whole person plans providers can act on immediately.

Priority 5: science-based information as a clinical tool

The ACP is right about this, too: patients are drowning in marketing-driven misinformation. And providers who disengage from the supplement conversation are not protecting their patients from that flood, they're simply leaving them in it without a guide.

Fullscript's resource library gives providers a tool to counter that: 150+ evidence-based guides, handouts, and infographics. Every medical statement is linked to its original source and reviewed by Fullscript's Medical Advisory Team. These are designed to be shared by providers, not discovered by an algorithm.

A fair question: how is content produced by a supplement platform different from content marketing dressed up as education?

The answer is structural. Clinicians have final say on what gets published. Each educational asset is based on a review of research available at the time of publication, updated regularly as new findings emerge, and fact-checked and medically reviewed by a topic expert. There is an editorial firewall between Fullscript's commercial interests and its medical content team. 

That is the difference between education and promotion and it is the difference that makes a provider comfortable handing this material to a patient.

Priority 6: The EHR gap

Beyond supplement regulations, the ACP also flags a gap in the electronic health record: most systems have no dedicated field for a patient's supplements, and no way to check them against a prescription.

A provider can write a patient's fish oil into a free-text note, if there is time, or leave it out entirely. The drug interaction alerts built into most EHRs watch only the drug side of the chart. A patient on warfarin can list fish oil in one field and never trigger a warning in the other, because nobody connected the two databases.

Closing the gap with Fullscript EHR integrations 

ACP wants EHR vendors to close that gap with dedicated, searchable fields for supplements, linked to the same interaction databases already used for drug-to-drug checks, so a provider gets a flag instead of a blank space.

Fullscript already built that connection. It integrates directly with Epic, athenahealth, among +30 other EHR integrations. In May 2026, University Hospitals became the first system to put Fullscript inside Epic's medication workflow, so supplements and prescriptions now sit in the same record, visible to any clinician who opens the chart.

Fullscript Assist can check that record before it drafts a plan. It helps you draft safe, and evidence-based patient plans, and if a patient on warfarin asks about fish oil, it flags the interaction and proposes an alternative right there, before the recommendation reaches the patient.

Your practice moves at your pace, but there’s so much that can slow you down. Fullscript Assist is the HIPAA-compliant clinical decision support AI that helps you draft patient plans — personalized, safe, and evidence-based — right in the flow. It accelerates your clinical expertise — without replacing it.

That is the difference between asking an EHR vendor to add a warning and giving a clinician a system that already knows to warn. The ACP wants the first. Fullscript already runs the second.

The Cost of Disengagement

Here is the reality the ACP paper is responding to, stated plainly:

• 74% of U.S. adults take supplements, with 55% being regular users. (Council for Responsible Nutrition, 2023)
• 92% of supplement users believe supplements are essential for health.

Meanwhile, the New York Times published an OpEd in October 2025 entitled "A Plea From Doctors: Cool It on the Supplements."

Fullscript sits at the nexus where these two truths converge. Patients are not going to stop taking supplements because a position paper told them to. The question is not whether they take them, it is whether their provider has any oversight when they do.

Self-prescribing is a dangerous practice: toxic dosage, interactions, quality issues, unwanted excipients, expired ingredients, misrepresented dosage. But getting the right ingredients for your body, at the right dose, under clinical supervision, can make a meaningful difference in health outcomes.

A provider who disengages from supplements does not make the problem disappear. They lose clinical oversight and cannot ensure the patient is getting the right therapeutic dose for whatever health condition they're trying to address. The patient is still in the market. They're just there alone.

What This Means for Your Practice

If you agree with the ACP's concerns, and you should, you have two options:

1. Wait for Congress and the FDA to build the infrastructure over years
2. Use the infrastructure that already exists

Even in a world where regulation fully works, a platform like Fullscript gives providers another layer of trust and a way to make supplements more accessible to their patients under correct supervision. 

The ACP published a paper describing the healthcare system supplements deserve. Fullscript built it.