Post-dating Opioid Prescriptions

[vitriol102]

Greetings!
Have had some new patients because their regular pain physician no longer accepts their insurance (and majority of local PCP flat out will not prescribe opioids). Apparently, for stable/compliant long term patients, their pain physicians used to give them post-dated opioid prescriptions (3-4 months). Now these patients are established with me, they are asking me to do the same.

The way I feel about this is that if the DEA does not want narcotics called in to pharmacies, then it makes sense they would not approve of post-dating Rx and giving it to pts so they don't have to come back for another 3-4 months.

Curious, how do you deal with this? Is it common practice to do this? And has anyone been burnt by post-dating Rx?

Thank you

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[lobelsteve]

If you do not know the rules and laws, for godsakes put down your pen.

How about you trying to get the correct answer from the dea website then what your state requires.

Once that is done you have a bare minimum of lawful opiate prescribing. Ratchet that back 200% and you will approach reasonable opiate prescribing.

 

[metadr]

Post dating of scripts is allowed up to 3 months of total meds. I believe it was originally meant for adhd kids not having to skip school for monthly appts. Chronic pain patients got lumped into that. Our current practice allows occasional 2-3 months of meds in stable low risk patients, but vast majority are monthly.

 

[lobelsteve]

Post dating of scripts is allowed up to 3 months of total meds. I believe it was originally meant for adhd kids not having to skip school for monthly appts. Chronic pain patients got lumped into that. Our current practice allows occasional 2-3 months of meds in stable low risk patients, but vast majority are monthly.

Interwebs. Ugh.

http://www.deadiversion.usdoj.gov/faq/mult_rx_faq.htm

No. You cannot post date the Rx.

 

[metadr]

Interwebs. Ugh.

http://www.deadiversion.usdoj.gov/faq/mult_rx_faq.htm

No. You cannot post date the Rx.

Didn't pay attention to the terminology (that's how rarely we do it). Meant to say post-dating the fill date, and not the prescription issue date... Thanks for correcting me.

 

[specepic]

I think the OP is asking if it is ok to provide 3 months of med or if pts need monthly OV. Postdating should not be done, but I often provide 'do not fill' dates on the RX for stable pts are seen q 12 weeks, and are given three 4 week rx's at a given visit. Fu OV is 12 weeks (or 1-2 days sooner) later.

 

[Ducttape]

I think the OP is asking if it is ok to provide 3 months of med or if pts need monthly OV. Postdating should not be done, but I often provide 'do not fill' dates on the RX for stable pts are seen q 12 weeks, and are given three 4 week rx's at a given visit. Fu OV is 12 weeks (or 1-2 days sooner) later.

The 'do not fill' is also State dependent, and some states do not allow.

The link lobelsteve posted needs to be reviewed.

A physician is allowed to write Code D prescriptions for greater than 30 day supply. Review your state regs on requirements...

 

[vitriol102]

Thank you for your replies.

Steve, I've seen a number of your posts and responses. You're a great source of info. Sorry if I offended you. Do my best to keep up with all the literature...but don't know everything so I ask and not assume...

Read the DEA website posted by Steve, still needed a few things cleared up. Called the regional DEA office. The officer said exactly what specepic's post reads: no post-dating, but it is ok to write: "do not fill until...."

Didn't stay on the phone too long with the DEA agent. Wasn't very friendly. But the above does bring up another question: how is doing the above different from calling in refills? Isn't the principle still the same? Yet one is allowed but the other is not.

 

[lobelsteve]

No problems....

DEA changed their mind in federal register when pressed on the topic. November 2005 they said that start dates were tantamount to refills and violated the intent of the CSA. Stakeholders met and got DEA to change to 90 days with Rx dated on day it was signed and start dates were acceptable.

 

[gasorrad]

1. a practitioner may issue three 30-day schedule II prescriptions to cover a 90-day supply or he/she may issue nine prescriptions for the same schedule II controlled substance, each for a ten-day supply, having the combined effect of a 90-day supply.
2. Each separate prescription must contain written instructions indicating the earliest date on which a pharmacy may fill each prescription.
3. Is post-dating of multiple prescriptions allowed?
No. Federal regulations have always required that all prescriptions for controlled substances "be dated as of, and signed on, the day when issued."

I'm a bit confused. The above info from DEA website sounds like it is contradicting itself.

 

[Ducttape]

No it is not.

You cannot postdate a script - ie write a script and date it with a future date. Postdating technically is a provider writing a script and dating it for, for example, Dec 1st of this year(it being october 9th atm).

The DEA will - state dependent, you MUST check state law - allow the provider to write a prescription and date it October 9, with the additional comment "do not fill by Dec 1st." My state thankfully does not allow.

Now that i have stated that, my suggestion is yo do neither, take a class or 4, attend a few of Jane Bolen's lectures on proper opioid prescribing, but first and foremost please put down the pen and stand back from the proverbial prescription pad...

For opioid prescribing, patient convenience never trumps federal or state law.

 

[gasorrad]

Ah I see I now get the difference. Practically how is it any different? I have actually never even seen anyone write a script with a future date. How is it different than writing a script with "do not fill till ..."?

 

[Aether2000]

Practically, there is no difference, but federal law requires the script be signed and written on the actual day. Doctors have lost their DEA license for encoding a future (and past) date on the dateline of the script.

 

[emd123]

Try to bring most patients back monthly. >90%. Allow a small few, the lowest dose, most compliant, long term patients come every two months with the second Rx having a "Do not fill date." Never post date. In rare, rare, circumstances (low dose patient, well known and reliable) do three months with "Do not fill dates" only if some legit, extreme example, like they're going out of town for 2 1/2 months due to some unavoidable circumstance.

Anything > 90 days is illegal. Anything > 30 days for the majority of patients, during a National prescription drug abuse epidemic, is likely not wise.

Just spoke to my local state DEA cop last week who emphasized two things. Checking the Rx database with every Rx and rechecking patients monthly in most circumstances.

During a National prescription abuse epidemic, tighten the reigns. Do not do the opposite. Do not allow patients to manipulate you into loosening the monitoring because their last doctor was lenient with prescribing.

 

[PainDrain]

May I just throw out that no matter how "low risk" a patient is are you willing to put your license, and career for that matter, in the line? I would never even think of writing for three month supplies. We, as a specialty, already draw enough attention, why risk it?

 

[ampaphb]

>90d is illegal for schedule 2 drugs. Tylenol with codeine and Butrans are schedule 3.

To be clear, I have never written more than a 90d supply on and controlled med, but the stickler in me felt the need to point out the above.

 

[Jcm800]

Just have them pick up a script written monthly by you for the two months in between. You don't need to see them if you are comfortable and they have proven themselves. But you can write the script with the appropriate date, and then dont have to write do not fill, etc. and you don't have to have three scripts out there. The months between visits, They call for a refill, you write it and They pick it up. This is often when I drug screen the "stable" patients, as they are not expecting it. That's random uds. You find many are not "stable"