I thought C III - V can be faxed only if the prescriber manually signs the rx ? Can anyone verify this or am I incorrect?
Allow me to share my understanding:
Reference: Checked on 03-09-2014:
http://www.pharmacy.ca.gov/licensing/prescribe_dispense.shtml
Exact quote is below, no change at all:
START OF QUOTE: ++++++++++++
"
Can a prescriber electronically transmit a Schedule III through V controlled substance prescription from a computer or personal digital assistant (PDA) to a pharmacy’s computer or fax machine?
Yes. Advice from the Drug Enforcement Administration in a letter from Patricia M. Good, Chief of the Liaison and Policy Section, Office of Diversion Control for the U.S. Department of Justice dated September 28, 2001, states that current DEA regulations allow for Schedule III, IV, or V controlled substances that are electronically created or transmitted, which includes PDA’s, either directly to a computer or via facsimile machine, be treated as an oral prescription. This means the prescription must be reduced to hard copy form by the pharmacist and retained for at least three years. Additionally, a pharmacist that receives an electronically transmitted prescription via facsimile, or other methods, must ensure the validity of the prescription prior to dispensing the controlled substance (Title 21, Code of Federal Regulations section 1306.21). Electronically transmitted prescriptions, including those sent via PDA, must contain an electronic signature of the prescriber."
++++++++++++ END OF QUOTE.
Exact quote is above, no change at all.
From the quote: I would like to bring your attention to these sentences:
"DEA regulations allow for Schedule III, IV, or V controlled substances that are electronically created or transmitted, which includes PDA’s, either directly to a computer or via facsimile machine, be treated as an oral prescription.
Electronically transmitted prescriptions, including those sent via PDA, must contain an electronic signature of the prescriber."
Now, we analyze these sentences:
"DEA regulations allow for
Schedule III, IV, or V controlled substances that are electronically created or transmitted, which includes PDA’s, either directly to a computer or via facsimile machine, be treated as an oral prescription.
That means to me as: If I see a script, I ask my self:
Is this
C3,4,5 (not C2)?
If yes, C3,4,5 (not C2), continue. If C2, stop. do something else.
If C3,4,5, AND faxed to pharmacy or electronically sent to my pharmacy, then, treat as phoned script.
What do we do with PHONED script? We reduce to writing.
What do we do with FAXED script? We reduce to writing.
BE CAREFUL OF THE LANGUAGE HERE:
Reduce to writing means:
show writing on paper.
Reduce to writing does NOT mean MUST HAND-WRITE.
Reduce to writing means: You can
type then print or
keep faxed paper, if you have words in writing on paper, you have done the action called "
Reduce to writing."
(Extra knowledge of computer: In case you do not know, in computer's world, we have something called E-FAX.
To save paper, you have the ability to receive FAX by computer AND just STORE IN YOUR COMPUTER, no paper out.
Why? Again, to SAVE PAPER.
Therefore, you can receive a fax and still have no paper. Fax, at this point, exists only in the computer.
You just have picture of the fax in your computer, just like an attachment of email. If you want to print, then, you print, then, you will have fax on paper.
I just want to share because you may not know such way exist to receive a fax.
Now, this way of TOTAL PAPERLESS is NOT allowed by pharmacy board. If your pharmacy does this (small pharmacy), the board wants you to print that fax out and keep REAL PAPER. That's what board means by REDUCE TO WRITING.) Then, after you have paper, verify with office, tech can date then sign (no need to waste time of pharmacist).
Therefore, in my practice, this is what I see and do daily:
If
PHONED script,
We can type in computer (for example, type in Microsoft Word, seen at small pharmacies), then, print, then caller must date and sign in ink (no need to waste time of pharmacist). Then, because it is phoned script, pharmacist must date and sign.
We can HAND WRITE, then, because it is phoned script, pharmacist must date and sign.
If faxed script, we keep the faxed paper (the paper was reduced to writing by printer, no need to hand write), then, call office to AUTHENTICATE (to avoid fakers making fake script), then, caller date and sign in ink (no need to waste time of pharmacist). Then, because it is phoned script, pharmacist must date and sign.
If
electronic script was sent electronically as data to computer, our computer printed out paper automatically. We keep the electronic print out as hard copy. We do
NOT need to DATE AND SIGN IN INK. We do
NOT need to call office to verify
(Why? Fakers can not hack my computer yet !!! I will be wrong soon !!!) (That's how I see and heard at chain pharmacy.
Anyone would like to point out that this is wrong in the law, please feel free to contribute, thank you in advance.)
(Side note about C2: Lately, we have C2 that were sent
Electronically straight into our chain computer. Computer printed out a paper automatically. In computer, we can see clearly the electronic script. In our hand, we have print out as hard copy to put label on then file. We do
NOT need to waste time to call to check with doctor or verify or authenticate with office, (per chain's policy from district meeting). I like this.)
Let's continue with the law from board's web site:
Electronically transmitted prescriptions, including those sent via PDA, must contain an
electronic signature of the prescriber."
That means to me as: script must have electronic signature.
That means: signature could be any of these:
signature could be REAL SIGNATURE (If faxed.)
signature could be STAMPED SIGNATURE (If faxed.)
signature could be SCANNED SIGNATURE (If made by computer.)
signature could be "Signed electronically by Doctor Computer, M.D on 01-01-2011, at time: 1:11 P.M."
With that in mind, let's go back to the original question from the original poster:
I thought C III - V can be faxed only if the prescriber manually signs the rx ? Can anyone verify this or am I incorrect?
If I receive a fax for controlled med, I will have 2 cases:
Case 1: If my fax is a PICTURE of a paper (image in the language of law), then, we often see picture with signature signed manually before the doctor faxed (or stamped signature). My job: my pharmacy employee must call office and verify (to avoid fakers making fake fax), then, caller must date and sign signature in ink. Then, because it is phoned script, pharmacist must date and sign.
Case 2: If my fax is a FORM that was
printed (FULLY computer generated) at the doctor's office, then, the signature could be anything (STAMPED, SCANNED, "Signed electronically..." My job: my pharmacy employee must call office and verify (to avoid fakers making fake fax), then, caller must date and sign signature in ink. Then, because it is phoned script, pharmacist must date and sign.
Either way, if faxed, it does not matter if doctor signed manually or not, my pharmacy employee must call office and verify (to avoid fakers making fake fax), then, caller must date and sign signature in ink. Then, because it is phoned script, pharmacist must date and sign.
Then, after we verify, we have done our duty to treat that fax as PHONED script. And remember, in PHONED script, it does not matter if the doctor signed manually or not.
Therefore, if faxed, signature or not, verify by phone. Then fax is legalized as PHONED script.
Why verify either case?
The law said so. Here's the proof:
Exact quote is below, no change at all:
START OF QUOTE: +++++++++++++++++++++++++++++++++++++++
http://www.pharmacy.ca.gov/licensing/prescribe_dispense.shtml
"Do I still have the option of faxing or phoning in a prescription for a Schedule III – V controlledsubstance?
Yes, prescribers can fax or phone in a prescription for a Schedule III – V controlled substance. However, a security feature on the new tamper-resistant security prescription form prints VOID across the face of the prescription when faxed, please use a regular prescription form for faxed prescriptions. Pharmacies will have to validate the faxed prescriptions."
+++++++++++++++++END OF QUOTE.
Exact quote is above, no change at all.
Let's BOLD UP THE LAST LINE:
"Pharmacies will have to validate the faxed prescriptions."
"PHARMACIES WILL HAVE TO VALIDATE THE FAXED PRESCRIPTIONS."
Therefore, if faxed, signature or not, verify by phone. Then fax is legalized as PHONED script.
Why my pharmacy employee can call and not me (the pharmacist)? The law said so.
Any one from my pharmacy can call. That means: clerk, tech, intern, pharmacist. Save time for pharmacist to triple check the med.
You worry? Check this out.
Source:
http://www.pharmacy.ca.gov/licensing/prescribe_dispense.shtml
Exact quote is below, no change at all:
START OF QUOTE: +++++++++++++++++++++++++
Who can authenticate a controlled substance prescription? For example, verify a stamped signature, verify a prescription that appears to be copy, verify a typewritten date on a controlled substance prescription, or verify the source of new faxed-in prescription.
Pharmacists using their professional judgment and training are responsible for interpreting and evaluating a prescription. However, at a pharmacist’s direction a pharmacy employee may contact the prescriber’s office to verify/clarify non-clinical information contained on a prescription; for example, is the fax/phone number that of the prescriber? Of course, a telephoned prescription must be received only by a pharmacist or pharmacist intern (under the supervision of the pharmacist). The pharmacist is responsible for the accuracy of all information on the prescription documents and the prescription medication dispensed.
+++++++++++++++++++++++++++++END OF QUOTE.
Exact quote is above, no change at all.
Let me discuss this sentence:
"Of course, a telephoned prescription must be received only by a pharmacist or pharmacist intern (under the supervision of the pharmacist). "
That means to me:
If PHONED SCRIPT with CLINICAL INFORMATION, then, only pharmacist or intern can receive that phone.
If pharmacy calls to legalize a fax which had no date, or had no signature, or to be sure no faker faxed that fax, then, NON-CLINICAL information is being checked here. Then, any pharmacy employee can call (paid employee or non-paid employee can call).
Case in point: tech gets REFILL AUTHORIZATION by phone every day. Pharmacist does not have to waste time for that. What information do we discuss during that conversation?
Office: Hi, I am calling from office of doctor Ana to authorize refill.
Pharmacy: Thank you for your call. What's patient's name, birthdate, medication name, how many times, your name?
Office: Patient is Benjamin, ..., medication name is Carvedilol 12.5 mg, refill is okayed 2 times only, my name is Office Employee, what is your name?
Pharmacy: My name is Pharmacy Employee. Thank you for your call.
What did we discuss here in this phone call?
Non-clinical information that is deep enough that involves medication's name and milligrams. Is that considered to be CLINICAL? No. Just because the medication is mentioned does not mean CLINICAL. In this case. We agree such phone call is NON-CLINICAL. Any one from pharmacy can call office and get refill authorization. The key NEW INFORMATION is: refill is okayed 2 times only. Any one that is smart enough to work in pharmacy as clerk or tech can receive that correctly. No need to waste time of pharmacist.
With same reasoning, if doctor forgot to sign, any one from pharmacy can call because signature is NOT CLINICAL.
With same reasoning, if doctor forgot to date, any one from pharmacy can call because date is NOT CLINICAL.
That's my understanding.
I may be wrong or I may be right.
Either way, I welcome your input, comments and sharing thoughts.
Thank you, my friends out there. DNH.
... i wish they would just tell you the result right a way im so freaking depressed after taking that. 
