Nebraska News: Controlled Substance Answers Here
Published in the February 2009 Nebraska Board of Pharmacy Newsletter
Looking for answers to your controlled substances or Drug Enforcement Administration (DEA) questions? DEA has a terrific Web site: www.deadiversion.usdoj.gov/. The site contains lists of controlled substances by schedule, order forms, new regulations, and much more. Of particular interest to pharmacists is the “question and answer” section, which clears up questions such as the issuance of multiple prescriptions for Schedule II controlled substances.
Here is what the Web site has to say about changing a controlled substance prescription: The prescribing practitioner is responsible in case the prescription does not conform in all essential respects to the law and regulations. However, a corresponding liability rests upon the pharmacist who fills a prescription not prepared in the form prescribed by DEA regulations. Therefore, after consultation with the prescribing practitioner, the pharmacist is permitted to add or change the dosage form, drug strength, drug quantity, directions for use, and issue date. The pharmacist is never permitted to make changes to the patient’s name, controlled substance prescribed (except for generic substitution permitted by state law), or the prescriber’s signature.
Keep in mind that DEA’s emphasis is to stop drug diversion. DEA is not out to interfere with legitimate medical or pharmacy practice. If you make a change on a Schedule II prescription, be sure to document why you changed it and that you got authorization from the prescriber.
Be sure to document your actions clearly and completely. The situation that seems so clear and reasonable now may not be retrievable in your memory six months from now.