Notice

The Federal Government via the Department of Justice’s Drug Enforcement Administration (DEA), has changed its regulations with regards to the Prescription Laws. This was announced via the Federal Registry Notices FR Doc 04-25469 [Federal Register: November 16, 2004 (Volume 69, Number 220)] [Notices] [Page 67170-67172] From the Federal Register Online via GPO Access [wais.access.gpo.gov] [DOCID:fr16no04-82]. This change went into effect immediately on November 16th, 2004. New regulations will now make it unlawful to continue the practice of providing patients with multiple schedule II narcotic prescriptions.

Refills of schedule II prescriptions--The August 2004 FAQ stated: "Schedule II prescriptions may not be refilled; however, a physician may prepare multiple prescriptions on the same day with instructions to fill on different dates.'' (Italics added.) The first part of this sentence is correct, as the CSA expressly states: "No prescription for a controlled substance in schedule II may be refilled.'' 21 U.S.C. 829(a). However, the second part of the sentence (italicized above) is incorrect. For a physician to prepare multiple prescriptions on the same day with instructions to fill on different dates is tantamount to writing a prescription authorizing refills of a schedule II controlled substance. To do so conflicts with one of the fundamental purposes of
section 829(a).

Code of Federal Regulations

Section 829. Prescriptions

Schedule II substances

(a) Except when dispensed directly by a practitioner, other than a pharmacist, to an ultimate user, no controlled substance in schedule II, which is a prescription drug as determined under the Federal Food, Drug, and Cosmetic Act, may be dispensed without the written prescription of a practitioner, except that in emergency situations, as prescribed by the Secretary by regulation after consultation with the Attorney General, such drug may be dispensed upon oral prescription in accordance with section 503(b) of that Act. Prescriptions shall be retained in conformity with the requirements of section 827 of this title. No prescription for a controlled substance in schedule II may be refilled.

Schedule II Substances: The drugs in this schedule have a high potential for abuse, a currently accepted medical use in the United States, and their use may lead to severe psychological or physical dependence. Most of Schedule II Substances have been known in the past as Class A Narcotic Drugs; some examples are: opium, morphine, codeine, dihydromorphinone, methadone (Dolophine), meperidine (Demerol), cocaine, oxycodone, Percodan, etc. Also included in this Schedule is any compound which contains in any form the substance of methamphetamines as an injectable liquid.

Changes to our practice

In order to comply with new federal laws and regulations, patients requiring schedule II medications will need to be seen for evaluation by the medical staff, on monthly bases. On each evaluation visit, a specific medication questionnaire will need to be answered by patients. Drug testing will be undertaken as per each practice’s guidelines or protocols. Once this process is completed, the patient may then receive a one month prescription of their pain medication, assuming that the process indicates that it is still warranted.