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Vermont News: Is a Prescription for "Office Use" Valid?
Published in the March 2007 Vermont Board of Pharmacy Newsletter
The simple answer is no. Prescription medication must be dispensed to a patient. If a pharmacist is transferring prescription medication to a physician’s office in order for the physician to dispense/administer the drug to the patient, then the pharmacist is acting as a drug distributor. Although the transfer of prescription medications is allowed from one licensee (such as a pharmacy) to another licensee (such as another pharmacy or a practitioner authorized to dispense/administer the product), it is not done by means of a prescription. Both the purchaser and seller are required to keep an invoice on record. The invoice must contain the name, strength, form and quantity of the drug, the date of sale, and the name and address of the seller and purchaser. The stock transfer of a prescription drug may not be done by a prescription.
If the product sold is a controlled substance (CS), there are additional requirements. The invoice must also include the Drug Enforcement Administration (DEA) registration number of both the seller and the purchaser. If a Schedule III, IV, or V CS is sold, the invoice generated must be filed so that it is readily retrievable from ordinary invoices. If a Schedule II drug is sold, the purchaser must give a DEA Form 222 to the supplier before the transfer can proceed.
A pharmacist does not have to register as a wholesale distributor as long as such sales do not exceed 5% of total sales.
