C2 without last name

[PikminOC]

I forgot to put patient last name on a c2. I called the pharmacy to ask them to add last name, but they say it will violate state and federal law.

It's ok, I will get them a new script. I'm so silly.

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[owlegrad]

This is why I love electronic scripts. Impossible to make this kind of (shockingly common) mistake.

 

[PikminOC]

This is why I love electronic scripts. Impossible to make this kind of (shockingly common) mistake.

I'd never done this before. Just too busy before holidays. Is it true its violation of law if I tell them the last name they can't put it in

 

[Wickett]

I'd never done this before. Just too busy before holidays. Is it true its violation of law if I tell them the last name they can't put it in

There are certain things we cant alter on C2s (date written, drug name, and patient name). We can change directions, strength, address etc, but I believe that's it.

 

[owlegrad]

I'd never done this before. Just too busy before holidays. Is it true its violation of law if I tell them the last name they can't put it in

DEA guidance on this is vague and unhelpful. My understanding is we can’t change drug name, doctor name, or patient name but to be honest I am not even confident I am correct about that. Does adding a last name count as changing the name? I would bet any amount of money that there is no clear answer to that question anywhere. Of course state law can be different than federal law as well making it impossible to answer your question completely without knowing your state.

And different pharmacists have different thresholds or understandings of the law. I would be willing to bet you have made this mistake before but the pharmacists just fixed it without making a fuss about it. I’ve seen it enough to know it happens very frequently. Everyone makes more mistakes than they realize and I bet most of them go undetected. I would hazard a guess that the majority of pharmacists would just fix this without even mentioning it and this time you and your patient were just unlucky enough to get someone who actually follows the law. Or perhaps they didn’t want to fill the script for whatever reason and the lack of a last name was just an easy out. I actually think I am guilty of using that excuse myself in my retail days.

 

[CetiAlphaFive]

I'd never done this before. Just too busy before holidays. Is it true its violation of law if I tell them the last name they can't put it in

Yup.
I also rejected prescriptions with stickers containing pt info from the ER

 

[Charcoales]

Someone might add it in if the rx is identical looking to all previous fills. But for new rx with no history at that pharmacy? Heck no...

 

[sfachine]

I always put the patient first the law second.Why wouldn't I fill it if the lady had ID or was a regular?I have not heard of any pharmacist losing their license over a clerical oversight. Not now and not with current corporate attitudes.I would be fired over "illegal altering of a controlled substance prescription".Why take a chance?If they complain I give them my DMs number. Let them take the heat.

 

[PikminOC]

Someone might add it in if the rx is identical looking to all previous fills. But for new rx with no history at that pharmacy? Heck no...

Its the same pharmacy she always goes to. Same meds. Not a high dose. Vyvanse 30 mg number 30

 

[PikminOC]

Prolly just a new pharmacist who is being super careful.

 

[Sine Cura]

There are limits to putting patient first.

What about *****s who don't even put ANY name on the script. Punt that **** back to them. Maybe then they'll learn not to **** up

 

[PikminOC]

There are limits to putting patient first.

What about *****s who don't even put ANY name on the script. At some point punt that **** back to them.

It doesnt matter to me. The patient is the one who has to go thru more hassle, and theyre in a hurry as college starts Tuesday.
I dont care either way. Was just interested.

 

[PikminOC]

I always put the patient first the law second.Why wouldn't I fill it if the lady had ID or was a regular?I have not heard of any pharmacist losing their license over a clerical oversight. Not now and not with current corporate attitudes.I would be fired over "illegal altering of a controlled substance prescription".Why take a chance?If they complain I give them my DMs number. Let them take the heat.

Im confused, which way are you leaning with this? You are saying things both ways.

 

[MilknCheerios]

If the patient is a regular that I recognize, same doc, same drug, strength, on time, and the doc even calls me to inform me of the error, I would just annotate and fill it.

 

[PikminOC]

It was a change in dose, a decrease, so an early fill.

 

[Wickett]

Yup.
I also rejected prescriptions with stickers containing pt info from the ER

Yea I get one of those every month or so. In OPs case if it wasn't a first time fill I'd probably just add the info and fill. ER stickers of pts info slapped on the rx.....nope.

 

[owlegrad]

Interesting. I like the patient stickers, so legible.

 

[Wickett]

Interesting. I like the patient stickers, so legible.

In Texas, the state board doesnt consider that to be a secure script.

 

[Twentytwelve2]

only the signature and date has to be in indelible ink in the doctor's handwriting- california

 

[PikminOC]

DEA guidance on this is vague and unhelpful. My understanding is we can’t change drug name, doctor name, or patient name but to be honest I am not even confident I am correct about that. Does adding a last name count as changing the name? I would bet any amount of money that there is no clear answer to that question anywhere. Of course state law can be different than federal law as well making it impossible to answer your question completely without knowing your state.

And different pharmacists have different thresholds or understandings of the law. I would be willing to bet you have made this mistake before but the pharmacists just fixed it without making a fuss about it. I’ve seen it enough to know it happens very frequently. Everyone makes more mistakes than they realize and I bet most of them go undetected. I would hazard a guess that the majority of pharmacists would just fix this without even mentioning it and this time you and your patient were just unlucky enough to get someone who actually follows the law. Or perhaps they didn’t want to fill the script for whatever reason and the lack of a last name was just an easy out. I actually think I am guilty of using that excuse myself in my retail days.

I actually keep carbon copies of my prescriptions and have not made this error before.

Yes I'm a dinosaur who keeps carbon copies of all of my script, noncontrolled too

 

[lord999]

DEA guidance on this is vague and unhelpful. My understanding is we can’t change drug name, doctor name, or patient name but to be honest I am not even confident I am correct about that. Does adding a last name count as changing the name? I would bet any amount of money that there is no clear answer to that question anywhere. Of course state law can be different than federal law as well making it impossible to answer your question completely without knowing your state.

And different pharmacists have different thresholds or understandings of the law. I would be willing to bet you have made this mistake before but the pharmacists just fixed it without making a fuss about it. I’ve seen it enough to know it happens very frequently. Everyone makes more mistakes than they realize and I bet most of them go undetected. I would hazard a guess that the majority of pharmacists would just fix this without even mentioning it and this time you and your patient were just unlucky enough to get someone who actually follows the law. Or perhaps they didn’t want to fill the script for whatever reason and the lack of a last name was just an easy out. I actually think I am guilty of using that excuse myself in my retail days.

https://nabp.pharmacy/wp-content/uploads/2016/07/DEA-missing-info-schedule-2.pdf

Correct, enforcement is specifically vague at the federal (as this current guidance indicates). Honestly, the pharmacist can use their judgment from the federals and cite this letter. Unfortunately, TX, MN, AZ, and CA are explicit about not changing or correcting names on a prescription in their practice acts (not even single to married names as it's come up). VA policy does allow for these changes, but it doesn't happen in practical terms due to ePCS.

And @Wickett is definitely correct about TX's policy on patient labels (although there is an exception for Class C to D and vice-versa within the same system). TX is unusually strict about it, even before the narcotics craze.

@TikiTorches the oversight of not writing a last name makes a schedule prescription unambiguously invalid (not just C-II). It is actually illegal for the pharmacist at the federal level to alter a name, but in policy guidance from DEA, they overlook technical violations given the relevant facts. C-II's have additional restrictions on editing, which they themselves are vague on whether adding a name is a correction or alteration. What it comes down to is whether the pharmacist is going to risk a major headache for your error, and unless the patient or you have a good relationship with that pharmacist, probably not. But it's unlikely the DEA ever finds out from a complaint from either the patient or you, what usually happens is that insurance audits the script, finds out it was corrected, then reports the pharmacist to avoid paying out on the script (they're jerks like that).

 

[mentos]

Some pharmacists do everything they can go avoid filling a C2.

 

[Sine Cura]

Why let it slide when 95% of the time prescribers have sense to put the minimum required information.

"everyone is busy"

DEA probably doesn't care unless scripts came from a pill mill or sanctioned prescriber, but then you have the BOP, third-party payer audits, and internal audits.

 

[297point1]

DEA probably doesn't care unless scripts came from a pill mill or sanctioned prescriber, but then you have the BOP, third-party payer audits, and internal audits.

You beat me to it...any auditor sent on behalf of a PBM or health plan would declare the script invalid and claw back the payment.

 

[CardinalGirl210]

Its the same pharmacy she always goes to. Same meds. Not a high dose. Vyvanse 30 mg number 30

why don't they teach doctor's basic law on writing scripts in medical school? Seriously sometimes a lot of serious mistakes are avoidable

 

[PikminOC]

why don't they teach doctor's basic law on writing scripts in medical school? Seriously sometimes a lot of serious mistakes are avoidable

I missed it once. You never made a mistake? Yeesh

 

[PikminOC]

Why let it slide when 95% of the time prescribers have sense to put the minimum required information.

"everyone is busy"

DEA probably doesn't care unless scripts came from a pill mill or sanctioned prescriber, but then you have the BOP, third-party payer audits, and internal audits.

Prolly more than 95 percent

 

[Wickett]

You beat me to it...any auditor sent on behalf of a PBM or health plan would declare the script invalid and claw back the payment.

Yea I worry a lot more about audits than I do about the DEA or board, in general.

 

[PikminOC]

Why let it slide when 95% of the time prescribers have sense to put the minimum required information.

"everyone is busy"

DEA probably doesn't care unless scripts came from a pill mill or sanctioned prescriber, but then you have the BOP, third-party payer audits, and internal audits.

Yes everyone is busy and everyone makes mistakes. Pharmacy and physicians alike. This is a small easily corrected one

 

[Rouelle]

Yes everyone is busy and everyone makes mistakes. Pharmacy and physicians alike. This is a small easily corrected one

Yep, easily correctable minor inconvenience. If this is the worst thing that happened all day, then it was a pretty good day.

 

[wagrxm2000]

why don't they teach doctor's basic law on writing scripts in medical school? Seriously sometimes a lot of serious mistakes are avoidable

I missed it once. You never made a mistake? Yeesh

So you do or don't know the law?

 

[RxPreceptor]

why don't they teach doctor's basic law on writing scripts in medical school? Seriously sometimes a lot of serious mistakes are avoidable

In Goodman and Gilman's, there is an appendix section with a how to write a prescription section....some helpful stuff along with a few good laughs (some advice that is NEVER used in practice...mostly not using abbreviations/writing out every word and actually including a diagnosis/indication)

 

[MilknCheerios]

It was a change in dose, a decrease, so an early fill.

Honestly, I'd probably still fill it. Everyone's jimmies are getting rustled about the board of pharmacy, audits, law, morality, semantics, but to each their own.

 

[PikminOC]

In Goodman and Gilman's, there is an appendix section with a how to write a prescription section....some helpful stuff along with a few good laughs (some advice that is NEVER used in practice...mostly not using abbreviations/writing out every word and actually including a diagnosis/indication)

What book is that?

 

[RxPreceptor]

What book is that?

You know....the bible of pharmacology....or you don't know because apparently no one reads books anymore/MD/RPh/etc. students just skate by through F'ing power point slides

 

[PikminOC]

Im an old doctor. I dont think we used that in med school but it was over a decade ago.

 

[Sine Cura]

So who's team DiPiro? G&G? KK?

 

[CardinalGirl210]

I missed it once. You never made a mistake? Yeesh

I’m actually asking a legitimate question, not chastising you. The fact that you don’t know this is illegal for a pharmacist to change is telling. Why don’t they teach this in medical school? I just had an MD argue with me that they can’t call in controls by phone. We are in TX. It’s perfectly legal. Her nurse did it half an hour before the MD called in and she’s arguing with me about it like she’s never read the law in all her years of practice.

Furthermore, why don’t most MD’s and nursing staff re-read a prescription before they hit send or let the patient leave the office with a hard copy that doesn’t make sense? Proofreading goes a long way!

I genuinely want to know, is this not something they teach in medical school?! In pharmacy school, we take semester of law and sit for a state/federal law exam. You cannot practice as a pharmacist without knowing and complying with the law.


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[CetiAlphaFive]

I’m actually asking a legitimate question, not chastising you. The fact that you don’t know this is illegal for a pharmacist to change is telling. Why don’t they teach this in medical school? I just had an MD argue with me that they can’t call in controls by phone. We are in TX. It’s perfectly legal. Her nurse did it half an hour before the MD called in and she’s arguing with me about it like she’s never read the law in all her years of practice.

Furthermore, why don’t most MD’s and nursing staff re-read a prescription before they hit send or let the patient leave the office with a hard copy that doesn’t make sense? Proofreading goes a long way!

I genuinely want to know, is this not something they teach in medical school?! In pharmacy school, we take semester of law and sit for a state/federal law exam. You cannot practice as a pharmacist without knowing and complying with the law.


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The real answer is that there's a lack of integrity and ethics among some MDs.

They do things because they know they can get away with them or because they assume someone else will fix the problem.

 

[Xenophylia]

On that note, recently has the (dis)pleasure of dealing with an on call Dr. dealing with a nursing home patient. Her husband (in the same facility) had passed away and the nurses were having a hard time settling her down so they didn't have to deal with her (aka standard nursing SOP). So they badger the on call Dr. who oks a stat lorazepam dose. In the absence of a written/e-rx or verbal (direct from the physician- NOT from a nurse) order I can't let nursing pull controls from their med locker. The on call doc told nursing not to bother him again NOR were we to call him to get a verbal (which we are more than willing to do). I told them if we couldn't contact him they were out of luck then as I couldn't take the word of a nurse for a verbal controlled rx. Hours later, the doctor calls and tells me "how dare we" delay treatment to one of his patients. I told him how the law worked (although it shouldn't be my job to do this). His response was that- for his patients- he IS the expert AND THE LAW and that we should do whatever he says pertaining to his patients. I then informed him there are plenty of non controlled sedatives (diphenhydramine and haldol were available) if he does not want to be "bothered" giving verbal rxs for controls and that we can't take the word of a nurse to dispense a controlled substance. Also mentioned that opiates and benzos aren't the only two classes of drugs (as that seems to be his general belief) and that picking a drug that isn't controlled med would be more likely to result in faster treatment of his patients in the future if he's unwilling to follow the ACTUAL law. LOL What a douche!

 

[johnpharm01]

There's good reason why the dr has to write the patient name, drug down and sign control rxs- it eliminates any plausible deniability as to who is responsible for the rx. Had a local physician get disciplined for having
staff put names on prefilled rxs for controls. Good luck to those of you on
this thread with low practice standards.