Jul 23, 2017
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In the near future, if C2 was sent as Electronic Prescription, then, we can forward. But how? Voice? Fax? Electronic?
(Note: you will see term EPCS, which means: Electronic Prescription for Controlled Substances = EPCS)

Website at drugstorenews.com wrote:

“As posted in the preambles of the [notice of proposed rulemaking] and the [interim final rule], an unfilled original EPCS prescription can be forwarded from one DEA registered retail pharmacy to another DEA registered retail pharmacy, and this includes Schedule II controlled substances,” Miller said in an email to National Association of Boards of Pharmacy CEO Carmen Catizone.

Email about C2 from DEA was retrieved from this link and is now included below.
ncbop.org/PDF/LMillerDEAGuidanceTransferofOnFileCSPrescriptions.pdf

Quote from email of DEA:
"an unfilled original EPCS prescription can be forwarded from one DEA registered retail pharmacy to another DEA registered retail pharmacy, and this includes Schedule II controlled substances."

Discuss all angles please...start your engine...
Abbreviation you may see:
If you see EPCS, it means: Electronic Prescription for Controlled Substances.
If you see IFR, it means: Interim Final Rule.
If you see NPRM, it means: Notice of Proposed Rule Making.
 

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zelman

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In the near future, if C2 was sent as Electronic Prescription, then, we can forward. But how? Voice? Fax? Electronic?
(Note: you will see term EPCS, which means: Electronic Prescription for Controlled Substances = EPCS)

Website at drugstorenews.com wrote:

“As posted in the preambles of the [notice of proposed rulemaking] and the [interim final rule], an unfilled original EPCS prescription can be forwarded from one DEA registered retail pharmacy to another DEA registered retail pharmacy, and this includes Schedule II controlled substances,” Miller said in an email to National Association of Boards of Pharmacy CEO Carmen Catizone.

Email about C2 from DEA was retrieved from this link and is now included below.
ncbop.org/PDF/LMillerDEAGuidanceTransferofOnFileCSPrescriptions.pdf

Quote from email of DEA:
"an unfilled original EPCS prescription can be forwarded from one DEA registered retail pharmacy to another DEA registered retail pharmacy, and this includes Schedule II controlled substances."

Discuss all angles please...start your engine...
Abbreviation you may see:
If you see EPCS, it means: Electronic Prescription for Controlled Substances.
If you see IFR, it means: Interim Final Rule.
If you see NPRM, it means: Notice of Proposed Rule Making.
Until our system is set up to forward the electronic Rx in an electronic format, I'm not touching this with a ten foot pole.
 
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KimChiSlap

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We don't have a method of forwarding it electronically at this time.....
Until we set it up to but in the future
 

Charcoales

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Don't do it. Not worth it to risk it. Only maybe if specifically said by higher-ups...
 

owlegrad

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Unless you mean DEA when you say "higher-ups", I would still say don't do it.
So the fact that the DEA has specifically said that it's okay isn't enough for you? What more do you want?
 
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genesis09

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The forwarding must be done electronically so the signature trail doesn't break. Until this is available, this ruling means nothing.
 
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owlegrad

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I don't get the thought process. The DEA issues a statement saying it is permitted to do X and people are upset that they didn't specify Y and Z? I mean do you think the DEA is trying to set you up to do something illegal so they can then bust you? If they don't express any limits on the statement "You may transfer this between pharmacies" why then assume that there are double-secret limits?
 
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Sine Cura

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Well obviously yes (on the question of meeting requirements) because e-prescribing as been a thing for years. You would think the certification process for transmitting controlled substance prescriptions electronically as required by DEA would also address aspects of forwarding electronic prescriptions.
 
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zelman

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I don't get the thought process. The DEA issues a statement saying it is permitted to do X and people are upset that they didn't specify Y and Z? I mean do you think the DEA is trying to set you up to do something illegal so they can then bust you? If they don't express any limits on the statement "You may transfer this between pharmacies" why then assume that there are double-secret limits?
Well, they said "an unfilled original EPCS prescription can be forwarded from one DEA registered retail pharmacy to another DEA registered retail pharmacy" right? Well, if I ask you to "forward" me an email and you call me and read me the email, do you think you've done what I asked?
 
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owlegrad

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Well, they said "an unfilled original EPCS prescription can be forwarded from one DEA registered retail pharmacy to another DEA registered retail pharmacy" right? Well, if I ask you to "forward" me an email and you call me and read me the email, do you think you've done what I asked?
If you hit reply instead of forward should I make you resend it so it says FW instead of RE?
 
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Apotheker2015

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Yes. And make it "reply all" for public shaming purposes.
Guys... guys... I see where there may be a gap in communication here. Sure, owlegrad has a valid point. The DEA said it's OK to do so. However, the reality is that no system is set up to forward e-scripts. That's why the statement is not making sense to many. The DEA failed to say "if your system is set up to maintain the integrity of the bla bla bla bla".
The closest you can get is to pull an e-script that's on hold at another location and fill it at your location within the same chain. That is still not forwarding. The moment you fax it or send it in any other way, it becomes invalid.
 

Lnsean

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Guys you cannot give a verbal or fax or whatever. The electronic signature stays with the original E-RX. The vendor would have to build this into their software to allow it. The DEA saying it's okay would open the door for this to happen...it doesn't mean you walk in tomorrow and give CVS a verbal transfer for Adderall. "Forwarding" an ERX would be the equivalent of the doctor mailing you the hard copy back in the day. It needs to be the original copy....not a faxed or verbal dictation. I would not touch this unless my state clearly defines it.
 

owlegrad

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Guys you cannot give a verbal or fax or whatever. The electronic signature stays with the original E-RX. The vendor would have to build this into their software to allow it. The DEA saying it's okay would open the door for this to happen...it doesn't mean you walk in tomorrow and give CVS a verbal transfer for Adderall. "Forwarding" an ERX would be the equivalent of the doctor mailing you the hard copy back in the day. It needs to be the original copy....not a faxed or verbal dictation. I would not touch this unless my state clearly defines it.
Ah so it is up to the software vendor, not the DEA, to give us permission to do this. Got it, thanks!
 
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Lnsean

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Ah so it is up to the software vendor, not the DEA, to give us permission to do this. Got it, thanks!
Sure they gave you the permission...but you don't have a way of doing it right now while still preserving the original copy. The tech has to catch up now that it's allowed. Before it wasn't allowed, so the vendors had no reason to put it in there. Electronic E-Scribe for CIIs were allowed for a while and many vendors did not implement it until months later and many doctors did not utilize it until like years later. This is basically the DEA telling software vendors that it is now okay to implement a forwarding feature into their softwares. Common sense dude.
 
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owlegrad

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Sure they gave you the permission...but you don't have a way of doing it right now while still preserving the original copy. The tech has to catch up now that it's allowed. Before it wasn't allowed, so the vendors had no reason to put it in there. Electronic E-Scribe for CIIs were allowed for a while and many vendors did not implement it until months later and many doctors did not utilize it until like years later. This is basically the DEA telling software vendors that it is now okay to implement a forwarding feature into their softwares. Common sense dude.
I respect your opinion, but I still disagree. If the DEA had some special process in mind that the vendors needed to follow I'm pretty sure they would release that information, not make it secret. It's common sense they they wouldn't tell you allowed to do something that you're not able to do. ;)
 

Lnsean

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I respect your opinion, but I still disagree. If the DEA had some special process in mind that the vendors needed to follow I'm pretty sure they would release that information, not make it secret. It's common sense they they wouldn't tell you allowed to do something that you're not able to do. ;)
But they have been notorious for being vague and ambiguous. That is because they usually like to make vague decisions and then let the state define the details. This has happened before with many other decisions that the DEA has handed down and it was left to the interpretation of each state's opinion on what the DEA wanted within that scope.

Anyway just my 2 cents....carry on.
 

trailerpark

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If Walmart wont let me transfer a Lyrica on hold, no way I'll have to ever worry about transferring C2s.
 
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Apotheker2015

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Ah so it is up to the software vendor, not the DEA, to give us permission to do this. Got it, thanks!
Not quite. The DEA says it's ok to do so and Surescripts figures out how to make it happen or if it can even happen with the technology currently available. So in other words, CVS is connected to Surescripts. Dr. Smith is connected to Surescripts. Walmart is also connected to Surescripts. Dr Smith sends you a C-II escript at CVS. However, your patient wants it filled at Walmart across the street. You have no way of sending it there because CVS and Walmart are not "linked" via Surescripts. So if you send it via fax, that does not meet EPCS requirements. You'd be sending a fax. You're not actually sending it via Surescripts. Thus, it's no longer an e-script.
 
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genesis09

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The DEA is saying it will be okay for the e-scribe programmers to add a forward button. You will be able to go into the options menu, pick a new pharmacy, and send it there. If properly implemented it could help with some of the issues surrounding eRx of C2s.
 

Apotheker2015

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The DEA is saying it will be okay for the e-scribe programmers to add a forward button. You will be able to go into the options menu, pick a new pharmacy, and send it there. If properly implemented it could help with some of the issues surrounding eRx of C2s.
Right. Exactly.
 
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Apotheker2015

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The DEA is saying it will be okay for the e-scribe programmers to add a forward button. You will be able to go into the options menu, pick a new pharmacy, and send it there. If properly implemented it could help with some of the issues surrounding eRx of C2s.
They could try being less vague, though. LOL, we won't see it in our lifetime.
 
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