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Re: beas-pss Schedule II narcotics

From: Jan Hamel (jhamel@eaaa.org)
Date: Mon Jun 23 2008 - 09:43:46 EDT


Carol,
I'm curious as to /what event(s) prompted/ the following Questions &
Answers re: Schedule II Controlled Substances?
Thanks,
jan hamel

Davis, Carol A wrote:
>
>
> *Questions & Answers*
>
> ------------------------------------------------------------------------
>
>
> *Issuance of Multiple Prescriptions for
> Schedule II Controlled Substances*
>
> 1. *What does this rule allow a practitioner to do?*
> <http://www.deadiversion.usdoj.gov/faq/mult_rx_faq.htm#1#1>
>
> 2. *What are the requirements for the issuance of multiple
> prescriptions for schedule II controlled substances?*
> <http://www.deadiversion.usdoj.gov/faq/mult_rx_faq.htm#2#2>
>
> 3. *Does this rule require or mandate a practitioner to issue
> multiple prescriptions for schedule II controlled substances?*
> <http://www.deadiversion.usdoj.gov/faq/mult_rx_faq.htm#3#3>
>
> 4. *What is the effective date of the rule change?*
> <http://www.deadiversion.usdoj.gov/faq/mult_rx_faq.htm#4#4>
>
> 5. *Is there a limit on the number of schedule II dosage units a
> practitioner can prescribe to a patient?*
> <http://www.deadiversion.usdoj.gov/faq/mult_rx_faq.htm#5#5>
>
> 6. *Is there a limit on the number of separate prescriptions per
> schedule II substance that may be issued during the 90-day time
> period?* <http://www.deadiversion.usdoj.gov/faq/mult_rx_faq.htm#6#6>
>
> 7. *How is the issuance of multiple schedule II prescriptions
> different than issuing a refill of a schedule II prescription?*
> <http://www.deadiversion.usdoj.gov/faq/mult_rx_faq.htm#7#7>
>
> 8. *Is post-dating of multiple prescriptions allowed?*
> <http://www.deadiversion.usdoj.gov/faq/mult_rx_faq.htm#8#8>
>
> 9. *What is expected of the pharmacist?*
> <http://www.deadiversion.usdoj.gov/faq/mult_rx_faq.htm#9#9>
>
> ------------------------------------------------------------------------
>
> *Q. What does this rule allow a practitioner to do?*
>
> *A*. A practitioner may provide individual patients with multiple
> prescriptions for the same schedule II controlled substance to be
> filled sequentially. The combined effect of these multiple
> prescriptions is to allow the patient to receive, over time, up to a
> 90-day supply of that controlled substance.
>
> *Q.* *What are the requirements for the issuance of multiple
> prescriptions for schedule II controlled substances?*
>
> *A*.* *Requirements for issuance:
>
> - Each prescription issued is for a legitimate medical purpose by an
> individual practitioner acting in the usual course of his/her
> professional practice.
>
> - The individual practitioner must provide written instructions on
> each prescription indicating the earliest date on which a pharmacy may
> fill each prescription
>
> - The issuance of multiple prescriptions is permissible under
> applicable state laws.
>
> - The individual practitioner complies fully with all other applicable
> requirements under the Controlled Substances Act and implementing
> regulations, as well as any additional requirements under state law.
>
> *Q. Does this rule require or mandate a practitioner to issue multiple
> prescriptions for schedule II controlled substances?*
>
> *A*. No. This rule does not require individual practitioners to issue
> multiple prescriptions or to see their patients only once every 90 days.
>
> *Q. What is the effective date of the rule change?*
>
> *A*. This rule became effective on December 19, 2007.
>
> *Q. Is there a limit on the number of schedule II dosage units a
> practitioner can prescribe to a patient?*
>
> *A*. There is no federal limit as to the amount of controlled
> substances a practitioner can legitimately prescribe. However, if a
> registered practitioner issues multiple schedule II prescriptions, he
> /she is limited to the combined effect of allowing a patient to
> receive, over time, up to a 90-day supply of a particular schedule II
> controlled substance.
>
> *Q. Is there a limit on the number of separate prescriptions per
> schedule II controlled substance that may be issued for the 90-day
> supply?*
>
> *A*. The rule does not stipulate how many separate prescriptions per
> schedule II controlled substance may be issued for the 90-day supply.
> It is up to the practitioner to determine how many separate
> prescriptions to be filled sequentially are needed to provide adequate
> medical care. For example, a practitioner may issue three 30-day
> schedule II prescriptions to cover a 90-day supply or he/she may issue
> nine prescriptions for the same schedule II controlled substance, each
> for a ten-day supply, having the combined effect of a 90-day supply.
>
> *Q. How is the issuance of multiple schedule II prescriptions
> different than issuing a refill of a schedule II prescription?*
>
> *A*. The issuance of refills for a schedule II controlled substance is
> prohibited by law. The use of multiple prescriptions for the
> dispensing of schedule II controlled substances, under the conditions
> set forth in the Final Rule, ensures that the prescriptions are
> treated as separate dispensing documents, not refills of an original
> prescription. Each separate prescription must be written for a
> legitimate medical purpose by a practitioner acting in the usual
> course of professional practice. Each separate prescription must
> contain written instructions indicating the earliest date on which a
> pharmacy may fill each prescription.
>
> *Q. Is post-dating of multiple prescriptions allowed?*
>
> *A*. No. Federal regulations have always required that all
> prescriptions for controlled substances "be dated as of, and signed
> on, the day when issued." *21 CFR 1306.05(a)*
> <http://www.deadiversion.usdoj.gov/21cfr/cfr/1306/1306_05.htm>.
>
> *Q. What is expected of the pharmacist when filling a prescription
> issued pursuant to this regulation?*
>
> *A*. Where a prescription contains instructions from the prescribing
> practitioner indicating that the prescription shall not be filled
> until a certain date, no pharmacist may fill the prescription before
> that date. In addition, when filling any prescription for a controlled
> substance, a pharmacist who fills multiple prescriptions issued in
> accordance with this regulation has a corresponding responsibility to
> ensure that each sequential prescription was issued for a legitimate
> medical purpose by a practitioner acting in the usual course of
> professional practice. *21 CFR 1306.04(a).*
> <http://www.deadiversion.usdoj.gov/21cfr/cfr/1306/1306_04.htm>
>
> ------------------------------------------------------------------------
>
>
> *Providers and interested Parties, please note the highlighted
> blue question regarding shedule II prescription physician orders.
> This is federal and the state law is the same. 90 Days is the
> allowed days of a prescription order but can be less at the
> physician's discretion. The CRMA curriculum will be corrected to
> reflect this.*
>
>
> *Carol Davis HSC*
>
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> Carol A. Davis HSC
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-- 
Janet A. Hamel, RN-HSC
Eastern Agency on Aging
450 Essex St.
Bangor, ME 04401
Phone : 207-942-2426
Fax : 207-941-2995
Jhamel@eaaa.org

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