DEA, Controlled Prescription, ADDRESS REQUIRED? Audits?

[HelpfulPharmer1]

Folks, your help and constructive comments please:
My technician somehow asked me this question which got me cornered and went on the internet to research.
The question was: I heard that Controlled Prescription must have ADDRESS in writing on the paper itself. True or not? Because if that's true, we have been violating that law for so many months with "scripts without address".

Research at DEA website showed these words which I bolded and underlined the words that got me worrying:
www.deadiversion.usdoj.gov/pubs/manuals/pharm2/pharm_manual.pdf

SECTION IX – VALID PRESCRIPTION REQUIREMENTS

To dispense controlled substances, a pharmacist must know the requirements for a valid prescription which are described in this section.
...
A prescription for a controlled substance must be dated and signed on the date when issued. The prescription must include the patient’s full name and address, and the practitioner’s full name, address, and DEA registration number.
...
Link of above text is:
www.deadiversion.usdoj.gov/pubs/manuals/pharm2/pharm_manual.pdf

So, I have presented DEA law.
At this point, the law shows that paper must have address of patient.

The question to us all: Does this mean we will have massive audits because at over 8 pharmacies I have worked at, we often fill paper without PATIENT'S ADDRESS on the paper itself? Any other law like state law that may help us to not get fine because of "not having address on paper"?

Please share your constructive opinions, research, findings, links....

Thank you very much!

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[BidingMyTime]

Yes, by law you must have the address, but this is something that you can verify with the prescriber and fill in yourself.

 

[Dr Wario]

Correct me if I am wrong, but as long as your electronic database links the script directly to a patient's profile while includes their address, that would satisfy the law. I believe this is spelled out in a later/earlier section.

 

[zelman]

I've heard the argument that the address that prints on the label CVS puts on the back of the prescription fulfills this requirement.

Luckily, in my state we are required to get an ID for all controlled substances, so I tell my techs to jot down the address with the ID #.

Anyone have thoughts on the "full name" requirement? For Mr. John Jay Smith, would J. Smith suffice? Or John J. Smith? Or John Smith? Or what if they're one of those error magnets that go by their middle name and it says "Jay Smith"?

 

[bobisnew]

I have worked as PIC retail for about 3 years, left> 6 months ago. Keep that in mind. This is from my experience - you should double check
Sorry if I overlooked something , not quite awake yet.....zelman, Today at 5:21 AM

Been audited (at different pharmacies, multiple times) by the state board, insurance (medicaid/medicare and other pbms), and once by dea. The DEA i do not have much experience with - they came in and do what they want, then they go.

Thus it depends on a few factors. Which state? Who is auditing? I'm in NJ.

All insurance and state-board audits will follow the DEA regulations - need to have FULL NAME and ADDRESS.
Examples I have been fined/warned for, missing pt zip code, missing first name ("Mr. Doe" is not ok).

• Now it also depends on your company policy and if you are authorized to accept Escrbied controlled Rxs. I say this because if you are - the full name and address is required already on it - thus when the HARD copy requirement for NJ is printed/filed the full name and address is already on it. DR MARIO
• If not authorized. Now if a pt drops an RX off and you scan the rx into your electronic system w/o an address - you can electronically write the missing info on it bc that is your most up to date RX. That way you do not have to go back and write it on the hard copy, as long as on either one has it. I was told this by a few PICs and an auditor. Another told me different. I did not argue - bc mgrs pay fines for the state board and i want the auditor happy. Before i left I made every control RX have FULL NAME and ADDRESS on it before I verified the rx to print - from what I know alot of other mgrs soon followed. ZELMAN ( I think NY is like that)
• If you have no electronic system there's only the hard copy of RX - which must have FULL NAME and ADDRESS

Yes you must have name on address on every control RX. What I dont know- is electronic copy ok. Or must you go back and write on both/rescan.

Also - I know NJ state came out with new RX standards - above may be out of date.

 

[BenJammin]

I was told by the TSBP that the sticker placed on the back of the prescription is not good enough to fulfill the address requirement. Front of the prescription must have the patient's address.

 

[bobisnew]

Agreed - what i was also referring to. Sticker didn't fulfill requirement.

 

[Travex]

I was told by the TSBP that the sticker placed on the back of the prescription is not good enough to fulfill the address requirement. Front of the prescription must have the patient's address.

True. One of the smaller labels found on the monograph for CVS does have the patient name + address that you can stick on the front though.

 

[SClENCE]

I am told that the address must be on it, and apparently the sticker is not enough because we've been warned in the past.

Do you guys initial C3's? Or would this vary by state?