Schedule II or CII drugs are defined as drugs that are likely to be abused. On June 1, 2010 the DEA revised regulations on accepting prescriptions on schedule II drugs to include the ability to accept electronic prescriptions.
However, many pharmacy business owners still don’t entirely understand their role when it comes to CII drugs and accepting electronic prescriptions for them.
Dispensing CII e-Scripts
For CII e-scripts to be successfully received the prescriber, intermediary electronic prescription company and your pharmacy must all be Electronic Prescribing of Controlled Substances (EPCS) certified to handle schedule II prescriptions.
When the prescriber enters a CII prescription, their software validates that they have done all that is necessary on their part, including the two-factor authentication protocol that electronically signs the prescription. The prescriber must also provide written instructions on each CII prescription issued along with a fill dated for the pharmacist.
Then, the prescription is checked again by the intermediary’s software. The intermediary is the system that receives the doctor’s prescription and transmits it to the appropriate pharmacy. For most community retail pharmacies, Surescripts is the intermediary that is responsible for transmitting the prescription securely. If a problem occurs with transmission the intermediary cannot convert the prescription to a fax like a standard e-script. Instead, they must notify the prescriber.
When your pharmacy software receives the prescription it should also have stops in place to ensure that all regulations have been followed in the last two processes. If the prescription is caught up at any point in this chain of system checks it will not show up in your pharmacy software for dispensation. If it passes through these three checks, you will fill it like you would any other electronic prescription.
Multiple Prescriptions and Post-Dated Fillings
As I’m sure you know it is against the law to refill a schedule II narcotic prescription. Therefore, prescribers will issue multiple prescriptions with future dates on them. These prescriptions can come through two approved methods, e-script or written. According to the DEA, they can do this up to three months in advance. However, some state regulations are different. For example, in Oklahoma prescribers can only issue CII prescriptions up to two months in advance.
When you receive multiple prescriptions for CII medications with future dates, first ensure that they are set to be filled within the lawfully allotted time in your state. Then, receive each into your software system with a note reminding you and your staff not to fill until the specified date.
If there is a future date on a prescription, under no circumstances should you ever fill before that date. Also, DEA regulations mandate that you “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)
Short Fills for CII e-Scripts
Short fills are permitted if the pharmacy has inadequate quantity of drug to fill the full prescription. The remaining portion may be filled within 72 hours of the first partial filling, if the initial partial filling occurred within 30 days of the issuance of the prescription.
If you are unable to fill the remainder of the prescription within 72 hours, you should contact the prescriber.
Short Fills for LTCFs
Short fills, including individual dosage units, are permitted for individuals in LTCFs or those that have been diagnosed with a terminal illness. For these patients it will be your responsibility to properly record the circumstances for each partial fill (LTCF or terminally ill) on the back of each prescription or other appropriate record and must include:
- Date of the partial filling
- Quantity dispensed
- Remaining quantity authorized to be dispensed
- Identification of the dispensing pharmacist.
If you would like investigate further or see if your state has amended any of the federal regulations, I encourage you to click on the links below. Also, if you have any questions that we didn’t answer, ask us in the comments. We’ll do our best to find an answer for you!