Reprinted from the April 2008 North Carolina Board of Pharmacy Newsletter.
The frequently asked questions section of the Board’s Web site provides guidance on changes that may be made to a prescription for a Schedule II controlled substance after consultation with the prescriber: http://www.ncbop.org/faqs/Pharmacist/faq_ChangestoSchIICS.htm. This guidance comes directly from a letter sent to boards of pharmacy by the Drug Enforcement Administration (DEA) in 2006.
A number of pharmacists have contacted the Board stating that DEA has passed a “new rule” on this topic and now prohibits any change to a Schedule II prescription. This is not so. The confusion apparently stems from a Pharmacist’s Letter article. Based on what Board staff knows about the Pharmacist’s Letter article, it is in error. The article seizes on one clause of one sentence in an introductory paragraph to the new rules governing “do not fill until” Schedule II prescriptions (detailed in the January 2008 Newsletter) and extrapolates from that a sea change in DEA policy.
That clause arguably could be read as saying all changes to Schedule II prescriptions are prohibited, but it is hardly the only interpretation that can be drawn in context. Moreover, any such change in DEA policy would be a substantial reversal that would not be communicated in a throw-away clause in a sentence preceding a rule on an entirely different topic. Unless and until the DEA issues a clear repudiation of its prior stance on Schedule II prescription changes, pharmacists should feel comfortable following the guidance on the Board’s Web site.