All schedule II prescriptions will require triplicates and retention for two years. See the
Texas Medical Association writeup about it. While I feel for patients with fractures and such, I cannot justify adding to or continuing the opioid addiction in our society. In the schedule III-IVcategories, we have available to us tramadol, tylenol #3, NSAIDs and I realize that they have their own potential for abuse. I also cannot justify retaining records for a two year period such that if one is missing I will on the end of a medical board penalty -- no thanks.
You guys still haven't shown me any evidence that you have to keep copies of prescriptions with the new forms. By the way the new forms are not triplicates. The new forms are just special prescription forms in a pad ordered from DPS. The newest version has barcodes as well. As per the instructions from DPS on my pre-2010 prescription pad the only record keeping it asks for is "Carefully record the control number appearing on your prescription forms in a secure place apart from the forms."
The TMA link you sent me says the following. There is no mention of triplicates or keeping copies of the new forms for 2 years:
On Aug 22, 2014, the US Drug Enforcement Administration (DEA) published a final rule in the Federal Register reclassifying drugs that contain hydrocodone combinations from Schedule III to Schedule II. The change will take effect Oct 6, 2014.
What does the new rule mean for physicians?
- Prohibits physicians from delegating to advance practice nurses (APNs) and physician assistants (PAs) authority to prescribe these drugs outside of a hospital or hospice setting.
- Prevents physicians from calling in prescriptions for these medications to pharmacies (except in emergencies, in which case oral transmission must be followed up with written prescription within 7 days- see Texas Health and Safety Code, Ch. 481 Controlled Substances Act. Sect 481.074. PRESCRIPTIONS);
- Physicians must use the official prescription pads from Texas Department of Public Safety (DPS) for written prescriptions;
- Prohibits refills of prescriptions for these drugs without a patient visit or consultation; and
- Physicians may issue prescriptions for Schedule II drugs for a maximum 90-day period. *
If I write a prescription for a hydrocodone combination product on Oct 5, 2014 (while it is still a Schedule III drug) and specify refills, will pharmacies honor those written under the Oct 5, 2014 prescription, or must I rewrite the prescription as a Schedule II drug with no refills?
Prescriptions for hydrocodone combination products (HCPs) that are issued before Oct 6, 2014 and that have authorized refills, may be dispensed in accordance with DEA rules until April 8, 2015. Both DPS and the Texas State Board of Pharmacy have indicated that refills authorized on prescriptions dispensed prior to Oct 6, 2014 will be honored.
How do I order the Official Prescription Program pads?
Forms may be ordered from DPS using the
official order form for prescription pads for practitioners. APNs and PAs (hospital setting or hospice only) must use this
official order form. Pads of 100 forms cost $9. Unfortunately, DPS does not offer an option for online credit card orders. The standard time frame for fulfillment is 30 days, however, the DPS has diverted additional personnel to process orders and is fulfilling orders in 15-20 days, on average. The form may be emailed, faxed to (512) 424-5380, or mailed to DPS:
Texas Prescription Program
PO Box 15888
Austin, TX 78761-5888
Contact DPS Prescription Control Program at (512) 424-7293 or the Regulatory Services Division at (512) 424-7293.
Do federal and state laws allow for e-prescribing of Schedule II drugs?
Yes, e-prescribing of controlled substances (EPCS) is legal. However, physicians need to use an EPCS-certified e-prescribing vendor and ensure the pharmacy in receipt of the EPCS is able to receive the prescription. Currently, EPCS in Texas is in the very early stages and still fairly rare.
Check which
e-prescribing vendors are certified for EPCS. Check
which pharmacies are able to receive EPCS.
For more information about e-prescribing of controlled substances, see
A Necessary Pain: e-Prescribing of Controlled Substances is Worth It from the July 2014 issue of
Texas Medicine magazine.
Can residents in a medical residency program in Texas write prescriptions for Schedule II drugs?
According to DPS, the physician-in-training (PIT) must contact their permit office, staff coordinator, or department in charge of approving its PIT prescribing authority. The medical training institution will provide to the DPS' Texas Prescription Program a letter or list on company letterhead (or via electronic document) the names of authorized PITs along with the Texas Medical Board PIT permit numbers. As a validation, the Texas Medical Board provides the Texas Prescription Program a monthly electronic file exchange with all current PIT permit holders. DPS has posted FAQs on their
website regarding the reclassification of HCPs.
- See more at:
http://www.texmed.org/Template.aspx?id=31794&terms=hydrocodone#sthash.CcFQfJQD.dpuf