Writing C-II Rx for 90 Days (Three 1-month Rx's) - Okay in RI?
You can now write for 3 monthly prescriptions of a C-II. One for now and two others with the specific instructions: “Do Not Fill Before xx/xx/xxxx”. This became legal 12/19/07 as described below.
DEPARTMENT OF JUSTICE
Drug Enforcement Administration
21 CFR Part 1306
[Docket No. DEA–287F]
RIN 1117–AB01
Issuance of Multiple Prescriptions for
Schedule II Controlled Substances
AGENCY: Drug Enforcement
Administration (DEA), Department of
Justice
ACTION: Final rule.
SUMMARY: The Drug Enforcement Administration (DEA) is finalizing a Notice of Proposed Rulemaking published on September 6, 2006 (71 FR 52724). In that document, DEA proposed to amend its regulations to allow practitioners to provide individual patients with multiple prescriptions, to be filled sequentially, for the same schedule II controlled substance, with such multiple prescriptions having the combined effect of allowing a patient to receive over time up to a 90-day supply of that controlled substance.
DATES: Effective Date: This rule is effective December 19, 2007.
This will hopefully be a question that fits into the Electronic Prescribing section soon. At this point it is a point for general discussion that I thought would be appropriate to post on the site.
The attached federal reference indicates that we can write 3 prescriptions for 1 month quantities if done in an appropriate format - at least that is my interpretation. The question is whether R.I. allows it. I have searched several times over the years and asked authorities that should have the answer - I have been unable to get written confirmation whether or not R.I. allows us to do it.
Answers
Thank you so much Dr. Braden for sharing the Title 21 document with everyone. This will be helpful to everyone.
For those who do not wish to review the entire document I have pasted the paragraph in which Dr. Braden previously referred to for quick reference:
(1) In prescribing controlled substances in schedule II, practitioners may write up to three (3) separate prescriptions, each for up to a one-month supply, each signed and dated on the date written. For those prescriptions for the second and/or third month, the practitioner must write the earliest date each of those subsequent prescription may be filled, with directions to the pharmacist to fill no earlier than the date specified on the face of the prescription.
Using an EHR?
Much appreciated.
Thanks Dr. Braden
Using an EHR? Yes - eClinicalWorks
Disclosure: Owner/practicing partner of Aquidneck Medical Associates, Inc. Contracted as the Case Management Physician Advisor at Newport Hospital (a Lifespan affiliate) and as an advisor for BCBS of RI to help facilitate HIT integration in community practices
The law as amended is at
http://www.rilin.state.ri.us/Statutes/TITLE21/21-28/21-28-3.18.HTM
and the relevant sections are at the end, paragraphs (l) and (m).
Using an EHR? No
I appreciate the information. Is it possible that you or someone else can provide links to the pertinent regulations? I am generally the one in my group to educate the physicians on matters such as this. I have a standard routine which is to provide copies and/or links to the regs along with a summary. Also, if I get pushback from the pharmacists, I need to have the regs "in hand" to quote or fax to them to avoid further confusion and patients being caught in the middle.
I look forward to viewing the regs.
Thanks again.
Using an EHR? Yes - eClinicalWorks
Disclosure: Owner/practicing partner of Aquidneck Medical Associates, Inc. Contracted as the Case Management Physician Advisor at Newport Hospital (a Lifespan affiliate) and as an advisor for BCBS of RI to help facilitate HIT integration in community practices
Yes, RI law was amended in Sept 2008 to conform to the Federal rules. Of course, no one bothered to notify the doctors or pharmacists, so there was a period of confusion.
RI law was amended again Sept 2009 (again without any effort to inform anyone affected) so that a 60 day supply of schedule II stimulants is no longer permitted (because with the ability to give 3 one-month scripts, it's no longer necessary). (Also, schedule IV drugs are now limited to 360 units in 3 months, not 100 units in a month; schedule III is still 100 units a month.)
Using an EHR? No