California Controlled substance forms - refill boxes required?

This forum made possible through the generous support of SDN members, donors, and sponsors. Thank you.

KennethCool

Full Member
5+ Year Member
Joined
Nov 30, 2017
Messages
101
Reaction score
59
I keep hearing from the other pharmacists that C2 RXs on Cali Controlled substance forms are not legit unless the have the "refill boxes."

I've looked through the law PDF on the board website and this does NOT seem to be anywhere written in the law. Have you heard of this?

Members don't see this ad.
 
http://www.pharmacy.ca.gov/laws_regs/lawbook.pdf

11162.1 (Page 358) have a list of items to have on prescription pads, the refill boxes is #10.

There's been an issue lately with nearby Walmarts rejecting all control prescriptions without the boxes and we were getting hit with an influx of their patients coming in to try their luck. There was an email sent out two days ago from board of pharmacy ([email protected]). I don't know if BOP posted it anywhere else, but the copy and paste of the email:

____
Background:
California Health and Safety Code section 11162.1 contains 14 elements that must appear on California Security Forms, the forms used to prescribe controlled substances in California*. These elements were first enacted in 2003 when the triplicate prescription form was discontinued. The law also requires that California Security Forms must be printed by CA Department of Justice licensed printers. In 2006, the law was amended again to make several changes that took effect in January 2007. Finally legislation enacted in 2011 required that the California Security Forms in use must be fully compliant with all requirements of the Health and Safety Code by July 1, 2012.

Here is a link to the required elements in the Health and Safety Code (go to page 357): http://www.pharmacy.ca.gov/laws_regs/lawbook.pdf




In recent years, the board has continued to identify noncompliant California Security Forms in use that have been filled by California pharmacies, in violation of the Health and Safety Code requirements.  The board’s response upon identification of noncompliant forms having been used to dispense controlled drugs is to educate the licensee, and to cite and fine the pharmacy/pharmacists involved. Typically the licensing board for the prescriber is advised as well.

Recently some pharmacies have begun to refuse to fill prescriptions written on noncompliant forms where item 11162.1(a)(10) is not fully compliant with the required elements. One of these elements is “ Check boxes shall be printed on the form so that the prescriber may indicate the number of refills ordered.” There are also additional elements missing on some forms, including lack of a watermark on the reverse of the form.

The board recently has received complaints from patients or prescribers whose patients have been denied medication from the pharmacy because of the noncompliant forms.

Interim Solutions

  • Prescribers and dispensers need to become familiar with the 14 required elements of the security prescription forms.
  • Prescribers with noncompliant forms should reorder compliant forms from a DOJ-licensed security printer.
  • Prescribers with noncompliant forms should consider using e-prescribing for controlled substances.


Additionally:

  1. Schedule III -V controlled substances may be filled (and refilled) if the pharmacist treats the prescription as an oral prescription and verifies orally with the prescriber the number of any refills ordered with notations on the security form.  
  2. California law provides that Schedule II drugs cannot generally be orally prescribed, nor can they be refilled using a California Security Prescription. However, when there is no alternative except to prescribe a Schedule II controlled medication using a noncompliant California Security Form to allow patients to receive their pain medications timely, prescribers and dispensers should communicate about why a noncompliant California Security Form is being used on a temporary basis.


*Please note this exception to the security forms requirements: controlled substances prescriptions written for patients with a terminal illness may be written on ordinary prescription forms pursuant to section 11159.2 of the Health &Safety Code – here is a link (see page 352): http://www.pharmacy.ca.gov/laws_regs/lawbook.pdf
_____

Then the question is... does it literally have to contain BOXES? There are prescriber forms that have "Refills: NR 1 2 3 4 5" where prescriber circles and it seems like Walmart has been rejected those too because there are no actual boxes. (Some patients have gotten creative and tried drawing the boxes in themselves, but we had to turn them away last week while we looked into the issue)
 
Last edited:
I keep hearing from the other pharmacists that C2 RXs on Cali Controlled substance forms are not legit unless the have the "refill boxes."

I've looked through the law PDF on the board website and this does NOT seem to be anywhere written in the law. Have you heard of this?

Look Harder

11162.1.

(a) The prescription forms for controlled substances shall be printed with the following features:
...
(10) Check boxes shall be printed on the form so that the prescriber may indicate the number of refills ordered.
 
Members don't see this ad :)
i thought this was common knowledge lol
 
This is not common knowledge but ultimately a failure of DOJ not to hold security printers accountable for a basic requirement. Like licensing boards have the resources to fine their licentiates for this (well except BOP...)

Preprinted check boxes for refills have been required since January 1, 2007. Yes for nearly 11 years. The prescriber's software cannot just print the boxes on pre-ordered security prescription forms.

I have been dealing with this since I started working in California and fortunately most of the local prescribers aside from some stubborn dentists and vets and Sacramento County DHHS have fixed their pads. Every security printer can generate the correct forms; prescribers are lying or are just lazy if they claim they can't order the correct forms.
 
i always feel so stupid explaining all the california laws to patients. boxes?! really, BOXES?!!? i feel like tamper resistant is all you should need. boxes don't make an rx tamper resistant or not. UGH! so annoying. and then you have to call the doc and waste all this time. a few years ago a ton of hard copies didn't have the right wording of "prescription is void if the number of blah blah blah is not noted." but it had to be the EXACT phrase. oye.
 
Yup, this is true. We got hit with BOP audit earlier this week, and got dinged on that. I told them that per our PIC, we are still accepting the older pads, but letting patients know to tell their docs that they need to get on the ball and get new pads before the year is out (that way, patients don't go without meds for silly reason). The inspector agreed with it. As an add-on, we are keeping a list of doctors that we have contacted, asking them when they are getting new RX pads.
 
Where was the BOP the last 10 years?

You can try to contact the doctors but the only way they'll change is if their patients get pissed off at them

Why are there even multiple vendors for security forms? You can handle it like Texas where you order official forms from TSBP...
 
Where was the BOP the last 10 years?

You can try to contact the doctors but the only way they'll change is if their patients get pissed off at them

Why are there even multiple vendors for security forms? You can handle it like Texas where you order official forms from TSBP...

Well, from what we hear, most of the other pharmacies in our area have outright refused to fill C2 meds on old scripts... that should get patients pissed off enough to spark change.
 
All the pharmacies in my area have rejected the CII scripts forcing a lot of the doctors to finally order new prescription pads. I fill and contact provider for my regulars, but won't accept any new patients with CII's written on noncompliant pads. Judging from the PDMP of the patients we turned away today, I'm guessing some pharmacists are also using this as an excuse to send away their problem patients.
 
This is not common knowledge but ultimately a failure of DOJ not to hold security printers accountable for a basic requirement. Like licensing boards have the resources to fine their licentiates for this (well except BOP...)

Preprinted check boxes for refills have been required since January 1, 2007. Yes for nearly 11 years. The prescriber's software cannot just print the boxes on pre-ordered security prescription forms.

I have been dealing with this since I started working in California and fortunately most of the local prescribers aside from some stubborn dentists and vets and Sacramento County DHHS have fixed their pads. Every security printer can generate the correct forms; prescribers are lying or are just lazy if they claim they can't order the correct forms.

I guess it's not a common knowledge if you've been a pharmacist for more than 11 years... they passed out booklets at chains for the new grads indicating whats required and it's stressed to know it for the board exams, so
 
A major hospital next to us still don’t do it... nothing we can do...
 
If all pharmacies stopped taking invalid scripts (because that's what they are by definition) from health systems (like Kaiser or UCSD or Santa Clara VMC) or hospitals they will be forced to change or patients will just stay within the health system. Again no standardization as Kaiser
"institutional forms" are correct but the regular forms are not for example

Then you have doctors who are mentally slow and don't get that the forms must already have all the "security features" present on the forms before writing on them or printing them.

This is all a waste of time easily avoided by having one vendor, one form or timely disciplinary action for prescribers
 
A major hospital next to us still don’t do it... nothing we can do...

Institutional pads have a different set of rules I believe. They can have pre-printed dates and no need for refill boxes.
 
Institutional pads have a different set of rules I believe. They can have pre-printed dates and no need for refill boxes.
I think you are right. I remember something about that too... was it any institution with more than 25 doctors or something? Lol
 
I think you are right. I remember something about that too... was it any institution with more than 25 doctors or something? Lol

They have a symbol on the form that will recognize it as "institutional" on the top right corner of the script. It applies to hospices, hospitals, SNFs, ERs...

So places like UCSD/UCI/UCLA don't need to have pre-printed boxes, or hand-written dates (pre-printed is completely fine). I think I've seen stores declined it and UCI reported the situation to the CA BOP and they emailed it to CVS and it says we have to accept these b/c they're institutional forms.
 
Check boxes for refills are always required. It's the set of check boxes for quantity that may be omitted for "institutional-style" forms.

Also all written Rx for controlled substances have to be signed and dated in ink regardless of whether the date is printed. (HSC 11164(a)(1)). This is why you see ED scripts with handwritten date in ink by the prescriber as pharmacists have consistently refused ED scripts without the hand-written date. (I suppose if you really want to be pedantic, toner is a type of ink so no wet signature required then?)

The above was covered in a BOP newsletter that shows the employees there don't even read the board's own regulations in reference to the "date in ink" requirement for controls. http://www.pharmacy.ca.gov/publications/12_mar_script.pdf

That said I have never encountered an "institutional-style" form that wasn't issued by an emergency department.
 
Last edited:
Ca BOP... making life needlessly and infinitely more difficult since the days of Old :yawn:
 
Ca BOP... making life needlessly and infinitely more difficult since the days of Old :yawn:
true dat.
Board of medicine is about protecting doctors.... BOP is about making our lives harder....
 
Top