Filling a C-II early... How serious of an offense is it on your license?

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ethyl

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I see insurance covering C-II scripts ~4 days early or so. I usually don't fill them if they're more than 2 days early, but what type of tracking or discipline goes on if you fill 3-4 days early on something like Adderall? Or Oxy/APAP with instructions for more frequent use.

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I see insurance covering C-II scripts ~4 days early or so. I usually don't fill them if they're more than 2 days early, but what type of tracking or discipline goes on if you fill 3-4 days early on something like Adderall? Or Oxy/APAP with instructions for more frequent use.

Can I ask you a silly question? Are you God all mighty? Your attitude sucks and worse it based on this:

ABSOLUTELY POSITIVELY NOTHING AT ALL

Does your state have a law that comports with your behavior? You are not the C-II police. You should not treat people who take medications like criminals. There must be some special gene that people who go to pharmacy school posses. This gene causes you to invent rules, regulations or laws that don't exist. Pharmacy is the most regulated field except for maybe nuclear power plants. You don't have enough rules to follow? You need to invent more? In Pennsylvania, for example, the law states:

A pharmacist may only renew a prescription at a reasonable time prior to the time when the contents of the prescription shall be consumed according to prescriber's directions.
The Pennsylvania Code.

That word, reasonable is a word you should acquaint yourself with. Your attitiude is anything but reasonable. Basically, if the insurance approves it, you should be good to go. My base line is 75% & up, depending on the drug, the patient's history and the original or last days supply dispensed and then I make an informed judgment.

Now picture a single mother overwhelmed with an autistic or hyperactive child who now has to make a second trip to the pharmacy after working all day because you are the friggin Adderall Nazi.
 
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...

That word, reasonable is a word you should acquaint yourself with. Your attitiude is anything but reasonable. Basically, if the insurance approves it, you should be good to go. My base line is 75% & up, depending on the drug, the patient's history and the original or last days supply dispensed and then I make an informed judgment.

...

75% and up? With regards to what?

No insurance involved in this scenario, lets just make it a cash transaction:
A 30-day supply of Adderall was dispensed on May 1, can you now sell the next prescription on May 26? What about May 27? May 28?
What is the arbitrary cutoff date? You can fill 3 days early, but not 4?
 
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75% and up? With regards to what?

No insurance involved in this scenario, lets just make it a cash transaction:
A 30-day supply of Adderall was dispensed on May 1, can you now sell the next prescription on May 26? What about May 27? May 28?
What is the arbitrary cutoff date? You can fill 3 days early, but not 4?

With very rare exceptions, most insurance plans use the 75% cutoff. Some use 85%. So on a 30 day supply anything less than a week is usually OK. If their insurance doesn't pay, I have to look at why (are they getting it elsewhere?)

At some point there is always a cut off date. That's the way the world works. You have to use your judgement and be reasonable. Unless your state law says otherwise, DON'T friggin invent regulations. They pay to use your professional discretion. There are people who try the early fill every month and those junkies have to just about use it all up.

The point is there is nobody in the history of the universe who got fined, cited or reprimanded becuase they filled an Adderall rx 26 days after they last filled a 30 days supply of Adderall.
 
LETS GO METS!


"Our father who art at Shea, Johan be thy name,
thy will be done, as it is in Cooperstown,
give us this day a frikkin win,
and forgive us our losses as we we forgive those who've **** on us,
lead us not into the record books but deliver us to the playoffs."

You are 5+1/2 games behind the Phillies who have just about everybody on the DL. Sucks to be you.....

Haliday, Hamels, Oswalt.... you don't have a chance. Well there is always next year....
 
You guys better be thankful you don't work in SC. We are the CII-V Nazis. If you dispense a 30 day supply of Adderall, you better wait 30 days to fill it again. If you have a 30 day supply of a CIII-V prescription with refills, you can refill it up to 48 hours early 1 time within the life of the prescription. After that, you would have to make the customer wait the full 30 days to fill it again. It really depends on your state laws. I doubt if there are any states more strict with controls than SC.
 
With very rare exceptions, most insurance plans use the 75% cutoff. Some use 85%. So on a 30 day supply anything less than a week is usually OK. If their insurance doesn't pay, I have to look at why (are they getting it elsewhere?)

At some point there is always a cut off date. That's the way the world works. You have to use your judgement and be reasonable. Unless your state law says otherwise, DON'T friggin invent regulations. They pay to use your professional discretion. There are people who try the early fill every month and those junkies have to just about use it all up.

The point is there is nobody in the history of the universe who got fined, cited or reprimanded becuase they filled an Adderall rx 26 days after they last filled a 30 days supply of Adderall.

:laugh: Looks like i struck a nerve with ya eh?
 
Maybe there's just more of a concern with C-II's here in Florida with the pain clinic epidemic. Governor Crist signed that recent pain clinic law that will track every controlled prescription filled in the state to detect abusers, shady pharmacies and MD's. The uncertainty behind that system of course causes fear and a desire to stay off the radar. Every pharmacist I've worked with here has the 'nazi rule' of filling no more than 2 days early.
 
Maybe there's just more of a concern with C-II's here in Florida with the pain clinic epidemic. Governor Crist signed that recent pain clinic law that will track every controlled prescription filled in the state to detect abusers, shady pharmacies and MD's. The uncertainty behind that system of course causes fear and a desire to stay off the radar. Every pharmacist I've worked with here has the 'nazi rule' of filling no more than 2 days early.

Show me the Florida rule, law or regulation. If you can't, you are colleagues are bunch of power happy a-holes who GIVE pharmacists a bad name. DON'T enforce or make up rules THAT DO NOT EXIST.
 
Ethyl the pharmacists you have worked with are not doing this to be *******s. They are doing it for a reason. They are following their state laws, or their recommendations from DHEC or a similar agency. It is a helluva lot more of a headache to check the last fill date of a CII or any other CS and explain to the customer the state laws involved, and why you are making them wait. It has absolutely nothing to do with being power hungry. Don't listen to that nonsense. I know because I do it every day here in SC. If someone got a 30 day supply of Xanax, they have to wait 30 days to refill it. The only exception is if the practitioner changes the strength or directions. Same for CIIs. Except there are no refills on CIIs. The patient has to get a new prescription from the MD. PAs and NPs are not allowed to write for CIIs in SC. I know this has nothing to do with your state, but my point is that some states have more strict laws than others. Besides, it's not worth your losing your license or getting fined because some toothless **** wants their dope early. States create these laws because people abuse this stuff. There are major drug abuse problems in the area I practice.
 
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Ethyl the pharmacists you have worked with are not doing this to be *******s. They are doing it for a reason. They are following their state laws, or their recommendations from DHEC or a similar agency. It is a helluva lot more of a headache to check the last fill date of a CII or any other CS and explain to the customer the state laws involved, and why you are making them wait. It has absolutely nothing to do with being power hungry. Don't listen to that nonsense. I know because I do it every day here in SC. If someone got a 30 day supply of Xanax, they have to wait 30 days to refill it. The only exception is if the practitioner changes the strength or directions. Same for CIIs. Except there are no refills on CIIs. The patient has to get a new prescription from the MD. PAs and NPs are not allowed to write for CIIs in SC. I know this has nothing to do with your state, but my point is that some states have more strict laws than others. Besides, it's not worth your losing your license or getting fined because some toothless **** wants their dope early. States create these laws because people abuse this stuff. There are major drug abuse problems in the area I practice.

There are major drug abuse problems everywhere. I pointed out you MUST follow your state laws/rules/regulations. It's easy to tell the junkies from the people who really need it. Adderall is not that much of an abused medication. It's not Oxycontin 80mg tid for healthy looking 22 year old who only gets that, Cyclobenzaprine and Xanax 1 mg, name brand.

Unless he can show me some Florida rule/law or regulation, I stand by my comments. Pharmacists have no business making up their own rules out of some misguided fear they will loose their license.
 
Maybe there's just more of a concern with C-II's here in Florida with the pain clinic epidemic. Governor Crist signed that recent pain clinic law that will track every controlled prescription filled in the state to detect abusers, shady pharmacies and MD's. The uncertainty behind that system of course causes fear and a desire to stay off the radar. Every pharmacist I've worked with here has the 'nazi rule' of filling no more than 2 days early.

Yea, the new scheduled medication database is a great concept on the surface, but inherently flawed. This is because pharmacies have 14 days to report fills. One could do a caddy-load of doctor shopping in that time. Until the system is real-time, it is a waste of time, and nothing more than a notch on Charlie's political belt.
 
21 CFR Part 1306 [Docket No. DEA–287F] RIN 1117–AB01
Issuance of Multiple Prescriptions for Schedule II Controlled Substances

http://www.doh.state.fl.us/mqa/pharmacy/info_dearuling.pdf

"...The Final Rule being issued today states expressly that, where a practitioner has issued multiple prescriptions in accordance with the rule, no pharmacist may fill any prescription before the date specified by the practitioner. The rule contains no exceptions to this requirement. In addition, because the CSA states that prescriptions for schedule II controlled substances must be written (21 U.S.C. 829(a)), the essential elements of the prescription written by the practitioner (such as the name of the controlled substance, strength, dosage form, and quantity prescribed, and—in the case of multiple prescriptions under this Final Rule—the earliest date on which the prescription may be filled) may not be modified orally."
 
21 CFR Part 1306 [Docket No. DEA–287F] RIN 1117–AB01
Issuance of Multiple Prescriptions for Schedule II Controlled Substances

http://www.doh.state.fl.us/mqa/pharmacy/info_dearuling.pdf

"...The Final Rule being issued today states expressly that, where a practitioner has issued multiple prescriptions in accordance with the rule, no pharmacist may fill any prescription before the date specified by the practitioner. The rule contains no exceptions to this requirement. In addition, because the CSA states that prescriptions for schedule II controlled substances must be written (21 U.S.C. 829(a)), the essential elements of the prescription written by the practitioner (such as the name of the controlled substance, strength, dosage form, and quantity prescribed, and—in the case of multiple prescriptions under this Final Rule—the earliest date on which the prescription may be filled) may not be modified orally."

Well this of course is obvious, but it has nothing to do with the situation at hand. We are discussing patient a getting a 30 day supply of Adderall on July 1. He presents another prescription on July26 dated July 24. Should you, could you, would you fill this? Please, people from the 4th Reich in SC, need not answer.. We know you can't, even if you wanted to.
 
Umm...is calling the doctor and asking him/her to fill it early count as an answer if they're paying cash :p?
 
Can I ask you a silly question? Are you God all mighty? Your attitude sucks and worse it based on this:

ABSOLUTELY POSITIVELY NOTHING AT ALL

Does your state have a law that comports with your behavior? You are not the C-II police. You should not treat people who take medications like criminals. There must be some special gene that people who go to pharmacy school posses. This gene causes you to invent rules, regulations or laws that don't exist. Pharmacy is the most regulated field except for maybe nuclear power plants. You don't have enough rules to follow? You need to invent more? In Pennsylvania, for example, the law states:

The Pennsylvania Code.

That word, reasonable is a word you should acquaint yourself with. Your attitiude is anything but reasonable. Basically, if the insurance approves it, you should be good to go. My base line is 75% & up, depending on the drug, the patient's history and the original or last days supply dispensed and then I make an informed judgment.

Now picture a single mother overwhelmed with an autistic or hyperactive child who now has to make a second trip to the pharmacy after working all day because you are the friggin Adderall Nazi.
sweet, I'm gonna tell all my Medicaid friends to bring their adderall, percs, and Oxys to your pharmacy. Now they can not only get a year supply for them selves but they also get 3 extra months of drugs per year they can sell!!!
Oh and cvs can suck your d$$$ because you just added 3 rxs per year for each regular maintainance narc you fill 7 days early.
You are a mean person! The op was asking what everyone else does and you call him a Nazi. I think you should move to Florida and open up an independent next to a pain clinic since you have no concern over the abuse and forgery of narcotics.
 
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sweet, I'm gonna tell all my Medicaid friends to bring their adderall, percs, and Oxys to your pharmacy. Now they can not only get a year supply for them selves but they also get 3 extra months of drugs per year they can sell!!!
Oh and cvs can suck your d$$$ because you just added 3 rxs per year for each regular maintainance narc you fill 7 days early.
You are a mean person! The op was asking what everyone else does and you call him a Nazi. I think you should move to Florida and open up an independent next to a pain clinic since you have no concern over the abuse and forgery of narcotics.

The question was about Adderall. I already pointed out you don't treat everyone who presents a CII prescription as a junkie. You know who the junkies are and only people who like a straw man argument raise issues unrelated to the OP or were already addressed.

Unless your state law says otherwise it is wrong to make a non-junkie patient wait until their entire prescription is exhausted before you fill the next one. I follow the laws of the Commonwealth of Pennsylvania. I reiterate again unless the laws of Florida state otherwise or your state laws/rules/regulations say otherwise, YOU ARE MAKING YOUR OWN RULES FOR SOME MAKE BELIEVE REASON THAT EXISTS ONLY IN THE MINDS OF PHARMACISTS WHO DON'T HAVE ENOUGH RULES TO FOLLOW SO THEY BURDEN THEMSELVES WITH IMAGINARY RULES.


Listen, I have turned away more fake prescriptions in the last 30 years than regular rxs you have filled. I don't fill prescriptions that are not for a legitimate purpose. I also don't make mom's of hyperactive kids, geriatrics with cancer or other legitimate patients make extra trips to the pharmacy to satisfy make believe rules...
 
You should be very worried. The DEA has agents posted outside every single retail pharmacy. They also have all the pharmacies bugged. You make one little slip up and the DEA swoops in and you disappear. Thats how the pharmacy shortage started you know. The DEA detained to many pharmacists for filling C-II's 4 days early instead of 3. Next thing you know there are not enough pharmacists. Now they take you away for weekend reeducation camps. Lots of brain washing a mind control. Sometimes you have been detained by the DEA and you don't even know it. Kind of like Zoolander. Go to a day spa for a week.

I would be very careful if I were you. Watch for the black helicopters following your evey move. You may not have much time left. If I were you I would really tighten things up. Refills only on the exact days they are due. In fact if I were you I would just turn away all prescriptions for controlled substances. You can never be to careful!

Remember the DEA is always watching...always.
 
You should be very worried. The DEA has agents posted outside every single retail pharmacy. They also have all the pharmacies bugged. You make one little slip up and the DEA swoops in and you disappear. Thats how the pharmacy shortage started you know. The DEA detained to many pharmacists for filling C-II's 4 days early instead of 3. Next thing you know there are not enough pharmacists. Now they take you away for weekend reeducation camps. Lots of brain washing a mind control. Sometimes you have been detained by the DEA and you don't even know it. Kind of like Zoolander. Go to a day spa for a week.

I would be very careful if I were you. Watch for the black helicopters following your evey move. You may not have much time left. If I were you I would really tighten things up. Refills only on the exact days they are due. In fact if I were you I would just turn away all prescriptions for controlled substances. You can never be to careful!

Remember the DEA is always watching...always.

I don't usually read your stuff, but this was just classic..... The best post I've read in a long time......
 
In reality, use your judgement. I don't sit there and count out how many days it has been since the last fill. I look at the days and day supply and if it seems reasonable, I'll fill. Just yesterday, I had someone who wanted a refill on their child's diazepam rx. However, it was just filled 5 days ago and it is a 15 day supply. I told them to come back in a week. Also, since the mother said they were almost all gone, I said, you must have been using them incorrectly. Giving such an amount to a child is too much. The tech and I thought she was probably sampling the drug.
 
In reality, use your judgment. I don't sit there and count out how many days it has been since the last fill. I look at the days and day supply and if it seems reasonable, I'll fill. Just yesterday, I had someone who wanted a refill on their child's diazepam rx. However, it was just filled 5 days ago and it is a 15 day supply. I told them to come back in a week. Also, since the mother said they were almost all gone, I said, you must have been using them incorrectly. Giving such an amount to a child is too much. The tech and I thought she was probably sampling the drug.

Judgment, reasonable? Are you sure you belong here? What a concept.....
 
sweet, I'm gonna tell all my Medicaid friends to bring their adderall, percs, and Oxys to your pharmacy. Now they can not only get a year supply for them selves but they also get 3 extra months of drugs per year they can sell!!!
Oh and cvs can suck your d$$$ because you just added 3 rxs per year for each regular maintainance narc you fill 7 days early.
You are a mean person! The op was asking what everyone else does and you call him a Nazi. I think you should move to Florida and open up an independent next to a pain clinic since you have no concern over the abuse and forgery of narcotics.

Now thats uncalled for...:laugh: We have a huge concern for these powerful drugs...We turn away many people for oxycodone everyday...
 
In SC, there are no refills on CIIs....

......I suggest you read over the FL law.

There are no refills on C-IIs anywhere in the United States, except for some hospice patients and then the number dispensed cannot exceed the number on the prescription.
 
Had a argument with a person coming to pick up his rx which were called in by a PA. Apparently, the PA said she would call in morphine. Obviously, that cannot be done. Had to tell the person it is illegal for that drug to be called in. The PA should have given you a written rx. So many prescribers do not know basic prescribing laws.
 
In NY, you cannot refill if the pt should have more than a 7 day's supply. So if they come in 7 days early on the first refill, that's fine. But now if they come in a day earlier next month, no dice.

Example: rx filled on 6/1, should last until 7/1, instead patient comes in on the 24th. We can fill since they have only a 7 day supply, but after filling, they now have 37 day's worth. Now they cannot get a refill before 8/23. If they come in on the 22nd, they'll have 8 day's worth left, so we can't fill it for them.

Of course this is tough to keep track of. We have a patient who gets oxycodone every month. We didn't get our shipment in when she was in, so we could only offer her a partial fill. She decided to go to the pharmacy across the road instead. Next month, she came back to us and asked "when can I get this filled? I know I have to wait 30 days." By our records, she hadn't gotten it filled in the past 55 days, so we could've filled it right there. We knew the deal with the partial from last month though, so we told her she had a few more days.
 
In NY, you cannot refill if the pt should have more than a 7 day's supply. So if they come in 7 days early on the first refill, that's fine. But now if they come in a day earlier next month, no dice.

Example: rx filled on 6/1, should last until 7/1, instead patient comes in on the 24th. We can fill since they have only a 7 day supply, but after filling, they now have 37 day's worth. Now they cannot get a refill before 8/23. If they come in on the 22nd, they'll have 8 day's worth left, so we can't fill it for them.

Of course this is tough to keep track of. We have a patient who gets oxycodone every month. We didn't get our shipment in when she was in, so we could only offer her a partial fill. She decided to go to the pharmacy across the road instead. Next month, she came back to us and asked "when can I get this filled? I know I have to wait 30 days." By our records, she hadn't gotten it filled in the past 55 days, so we could've filled it right there. We knew the deal with the partial from last month though, so we told her she had a few more days.

How do you fill a partial for a CII?
 
How do you fill a partial for a CII?
If the prescription is for 120 pills and you only have 100 in stock, you can offer them the 100, but they cannot get the balance. Actually, according to Federal and some state laws, you can partial, but the balance must be dispensed within 72 hours. Since nobody can keep track of the 72 hour thing, nobody does it.
 
How do you fill a partial for a CII?

If the prescription is for 120 pills and you only have 100 in stock, you can offer them the 100, but they cannot get the balance. Actually, according to Federal and some state laws, you can partial, but the balance must be dispensed within 72 hours. Since nobody can keep track of the 72 hour thing, nobody does it.
I believe it actually was for 120, we had 20 on hand and were getting a shipment the following day. She couldn't be bothered with two trips though, so she went across the street.
 
If the prescription is for 120 pills and you only have 100 in stock, you can offer them the 100, but they cannot get the balance. Actually, according to Federal and some state laws, you can partial, but the balance must be dispensed within 72 hours. Since nobody can keep track of the 72 hour thing, nobody does it.

Ya, I thought you meant that you gave her a partial and a balance. I was wondering who would be brave enough to do that.
 
If the prescription is for 120 pills and you only have 100 in stock, you can offer them the 100, but they cannot get the balance. Actually, according to Federal and some state laws, you can partial, but the balance must be dispensed within 72 hours. Since nobody can keep track of the 72 hour thing, nobody does it.

I do it all the time. This is of course another area where all the Pharmacist/backyard laywers weigh in. The federal law is quite clear. You can partial a C-II as long the balance is filled within 72 hours. Say today I receive a script for 240 Oxy/Apap 7.5/325 and I only have 120 on hand. I very clearly explain to the patient I do not have enough but can order it. I also explain if my order does not come in for what every reason be it an act of God or otherwise they cannot get the rest. I stress this about three times and tell them the choice is thiers or they can go somewhere else.
 
I do it all the time. This is of course another area where all the Pharmacist/backyard laywers weigh in. The federal law is quite clear. You can partial a C-II as long the balance is filled within 72 hours. Say today I receive a script for 240 Oxy/Apap 7.5/325 and I only have 120 on hand. I very clearly explain to the patient I do not have enough but can order it. I also explain if my order does not come in for what every reason be it an act of God or otherwise they cannot get the rest. I stress this about three times and tell them the choice is thiers or they can go somewhere else.

Yeah in Alaska though pharmacists can write for CII's so it doesn't matter if the order comes in or not. So honestly if anyone wants to solve this dilemma just move to Alaska. They don't even require an MPJE either, just dancing polar bear target practice.
 
Not to mention you can see Russia from there.
 
I do it all the time. This is of course another area where all the Pharmacist/backyard laywers weigh in. The federal law is quite clear. You can partial a C-II as long the balance is filled within 72 hours. Say today I receive a script for 240 Oxy/Apap 7.5/325 and I only have 120 on hand. I very clearly explain to the patient I do not have enough but can order it. I also explain if my order does not come in for what every reason be it an act of God or otherwise they cannot get the rest. I stress this about three times and tell them the choice is thiers or they can go somewhere else.

We use CSOS...We always partial and get next day shipment when the need occurs...I havent filled out DEA 222 paper form since I left CVS! Its great!
 
If the prescription is for 120 pills and you only have 100 in stock, you can offer them the 100, but they cannot get the balance. Actually, according to Federal and some state laws, you can partial, but the balance must be dispensed within 72 hours. Since nobody can keep track of the 72 hour thing, nobody does it.

We can keep track since we're not filling 400 daily! CSOS helps too...
 
We can keep track since we're not filling 400 daily! CSOS helps too...

I'm being a smart alec. When I was an independent we did this all of the time. CVS frowns upon this, though I did it from time to time when I was a PIC.
 
I'm being a smart alec. When I was an independent we did this all of the time. CVS frowns upon this, though I did it from time to time when I was a PIC.

you smart alec u! lol...CSOS is soooooo much better than those damn forms!
 
A pharmacist in my state was recently disciplined for filling a Vicodin prescription too soon. That was the first time I had seen that happen. I try to use reasonable judgment in the filling of controlled substances based on a case by case basis. I do think that filling them too early can become problematic even if they do go through on insurance. If someone is getting 120 Norco every month, and fills it after the 75% point each time, within three months they have taken an extra 90 tablets beyond what was prescribed. Obviously, there are cases where there are legitimate reasons to fill something early, or people that aren't likely abusing the medication. However, when certain people are regularly filling them that early, there is no doubt that they are taking all the extra tablets and going well beyond the prescribed dosage.
 
A pharmacist in my state was recently disciplined for filling a Vicodin prescription too soon. That was the first time I had seen that happen. I try to use reasonable judgment in the filling of controlled substances based on a case by case basis. I do think that filling them too early can become problematic even if they do go through on insurance. If someone is getting 120 Norco every month, and fills it after the 75% point each time, within three months they have taken an extra 90 tablets beyond what was prescribed. Obviously, there are cases where there are legitimate reasons to fill something early, or people that aren't likely abusing the medication. However, when certain people are regularly filling them that early, there is no doubt that they are taking all the extra tablets and going well beyond the prescribed dosage.

I would bet a jelly doughnut that the pharmacist in question was not disciplined for filling a Vicodin prescription early one time. In order to be sanctioned by the board, you usually have to be more egregious than that.
This whole thread amounts to the pharmacist acting like the highly trained professional he/she is supposed to be an exercising reasonable judgment while discharging his/her duties. And as Forest Gump would say, "That's all I have to say about that."
 
I would bet a jelly doughnut that the pharmacist in question was not disciplined for filling a Vicodin prescription early one time. In order to be sanctioned by the board, you usually have to be more egregious than that.

The disciplinary report read as if it was a single incident, however there did appear to be some other unrelated violations. It may very well be the case that it wouldn't have resulted in disciplinary action on it's own.
 
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