Calling Iowa pharmacist

[pharm202]

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I have a quick question about Iowa law that I can’t find a clear answer to...

Is there a max day supply for a single c2 prescription?

I always thought that there was not a limit to the quantity of tabs/caps the prescribed can right for on a single c2 prescription but a single c2 prescription can only be written for a max 30 day supply. From my understanding of the prescriber wants to give the pt a 90 day supply of a c2 they would have to write 3 sequential 30 day prescriptions.

The other day I had a pt come in for a 90 day supply of norco written on a single prescription. Well technically it was written for 90 tabs and instruction to take half a tab daily for a 180 day supply. This pt gets this prescription fairly regularly in the past- it usually last more than 90 Days but it is alswaya written the same way. It is usually only filled for 45 tabs due to insurance limiting it to a 90 days supply. But I thought we need to call to get the quantity changed on c2 prescriptions.

I questioned this prescription but could not find in the law that it specifically said that a single c2 prescription had a max day supply. However it does says that if I described wants to give a pt a 90 day supply of a c2 they can right sequential prescriptions to make a 90 day supply so I assume a single c2 prescription can not be written for 90 days. I asked the rx manager and they said it was fine and to fill the rx and I did because they have done this in the past but i was not 100% that this is legal.

Would some one be able to help clarify this?

 

[BidingMyTime]

From what I understand, under federal law, a prescriber can give a 90 day supply of a CII, or they can give 3-30 day RX's. IL limits to 30 day supply on CII, I'm not sure about Iowa law, but I'm guessing it doesn't, since other pharmacists have filled the 90 days in the past.

 

[Niosh]

Iowa law defers to federal on the quantity limits on CIIs, and federal law has no limit on the quantity given the prescription is otherwise legal. I called the board back when I was a student about this because I had the same question and that is what they told me.
Iowa does have the multiple prescription issuance law where then they would be limited to three 30 day supply prescriptions. My understanding is that this only applies if they are issued multiple prescriptions, so they could just as easily write for one 90 day supply prescription (or more days if it was medically appropriate).

 

[owlegrad]

No federal limit, as others have said.

Sent from my SAMSUNG-SM-G920A using SDN mobile

 

[Sine Cura]

Multiply issued "sequential" prescriptions can be any number of scripts up to a 90 day supply (not just 3 Rx each covering 30 days)

Interestingly this what the DEA said about quantity limits on CII for multiply issued prescriptions (I have included line breaks for ease of reading) (source: Rules - 2007 - Issuance of Multiple Prescriptions for Schedule II Controlled Substances)

As to the comment that DEA should allow multiple schedule II prescriptions for unlimited days' worth of schedule II controlled substances, as DEA explained in the NPRM, for the proposed rule to be legally permissible, it must be consistent with the text, structure, and purposes of the Controlled Substances Act (CSA). [emphasis mine] In this regard, 21 U.S.C. 829(a) states: "No prescription for a controlled substance in schedule II may be refilled."

By comparison, subsection 829(b) states that, for a schedule III or IV controlled substance, a prescription may be refilled up to five times within six months after the date the prescription was issued. Thus, Congress clearly mandated greater prescription controls for schedule II substances than for schedule III and IV substances. [emphasis mine]

For example, a physician may--consistent with the statute--issue a prescription for a schedule III or IV controlled substance and indicate on the prescription a certain number of refills. In this manner, a physician may provide a patient with up to a six- month supply of a schedule III or IV controlled substance with a single prescription indicating five refills. The same cannot be done with a schedule II controlled substance since section 829(a) prohibits refills. The statute requires a separate prescription if the physician wishes to authorize a continuation of the patient's use of a schedule II drug beyond the amount specified on the first prescription.

Thus, if DEA were to allow multiple prescriptions for an unlimited days' worth of schedule II controlled substances, the controls for prescribing schedule II controlled substances would be less stringent than for schedule III and IV controlled substances--a result that would conflict with the purpose and structure of the CSA. [emphasis mine] DEA believes that the 90-day limit, under the terms specified in the proposed rule, strikes a fair balance that takes into account the limitation imposed by Congress under section 829 as well as the general structure of the statute, which imposes greater controls for schedule II substances than those in lower schedules.

So if you had a single Rx for say a 100-day supply of a CII (looking at you Kaiser), a DEA agent might look askance at that (even without any explicit day supply restriction on a CII) as it is a single Rx whose day supply exceeds the total day supply permitted by the multiple prescription rule (90 days), which in turn was set at a seemingly arbitrary 90 days based on the idea that the DEA didn't want to be too permissive about the total day supply of CII compared to CIII and CIV