electronic transfer of CII, confusions, help needed

[firework]

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The following are copied from Oklahoma state board website under FAQs:

Can a pharmacy transfer "on hold" CDS prescriptions?​

The Drug Enforcement Administration (DEA) has issued a statement allowing pharmacies to transfer “on-hold” Schedule II-V electronic prescriptions from one pharmacy to another if they had not been filled at the original pharmacy. However, they require the transfer to be done electronically and the EPCS software does not permit pharmacies to transmit prescriptions from one pharmacy to another. Fax transmittal is not considered to be electronic transmission. If software is changed to accommodate the requirements of EPCS, then “on-hold” CDS prescriptions may be transferred between pharmacies.​

Can a pharmacy transfer "on hold" CDS prescriptions?​

Yes. If the pharmacy and the prescriber have the appropriately credentialed software then you are able to accept any prescription through that system. However, you cannot transfer a CII prescription to another pharmacy if you are unable to fill it. The doctor will need to re-transmit it to the new pharmacy.​

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Simple question: electronic transfer of unfilled CII between pharmacies is allowed or not? If both use EPCS.

 

[zelman]

Simple question: electronic transfer of unfilled CII between pharmacies is allowed or not? If both use EPCS.

Yes. However, as far as I know, there is no such software.

 

[Twentytwelve2]

I interpret that as a yes as long as it is from the same pharmacy chain (therefore electronically). California does not allow this though.

 

[firework]

Yes. However, as far as I know, there is no such software.

There's no pharmacy system that allows Electronic Prescribing of Controlled Substance? That can't be true unless I understand it totally wrong.

 

[rxkrafted]

There's no pharmacy system that allows Electronic Prescribing of Controlled Substance? That can't be true unless I understand it totally wrong.

keyword is CII

 

[Subvisual]

There's no pharmacy system that allows Electronic Prescribing of Controlled Substance? That can't be true unless I understand it totally wrong.

No, there needs to be a special software documenting the internal transfer of the prescription from one pharmacy to another (presumably similar to the one that prescribers use to send e-Rxs to the pharmacy). Which seems to not exist on any system that I know of.

 

[RxPreceptor]

Agreed with others; not aware of any chain currently having software that allows internal transfer of C2s

 

[genesis09]

DEA did make a statement if theoretically, someone was to make a program which would transfer C2 electronically, if would be legal. My guess they did this because of the push for electronic prescribing of controls. This solves one of the major issues of when a prescriber sends an erx to a pharmacy which doesn't have it.

 

[projektreverb]

TLDR: figure out how to fix this software problem and sell it. Do I hear $$$?

 

[zelman]

There's no pharmacy system that allows Electronic Prescribing of Controlled Substance? That can't be true unless I understand it totally wrong.

Receiving eRx, yes. Sending eRx, no. Get it?

 

[projektreverb]

Receiving eRx, yes. Sending eRx, no. Get it?

Oddly enough, I’ve worked with a system that allowed you to pull a C2 from another location in the same chain. In the process, it also deactivated it. I found this out when another store called asking me to pull back a C2.... after they had pulled it themselves and cancelled it. Luckily I caught it and told them to deal with the angry patient.

 

[firework]

My real question is here:

.......they require the transfer (of schedule II - V ) to be done electronically and the EPCS software does not permit pharmacies to transmit prescriptions from one pharmacy to another........However, you cannot transfer a CII prescription to another pharmacy if you are unable to fill it.​

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It’s saying you can transfer but you can’t transmit, but wait, you can’t transfer.

 

[firework]

Oh, I think I get it. You can’t transfer out, only receiving pharmacy can transfer in? But that doesn’t make sense. It’s like sneaking into another pharmacy and stealing out script. How would I even know if it’s requested by patient or just someone want to mess with me ?

 

[firework]

Receiving eRx, yes. Sending eRx, no. Get it?

I get it. Thanks

 

[zelman]

Oh, I think I get it. You can’t transfer out, only receiving pharmacy can transfer in? But that doesn’t make sense. It’s like sneaking into another pharmacy and stealing out script. How would I even know if it’s requested by patient or just someone want to mess with me ?

If the system existed, you would send the eRx from your pharmacy to another. They would receive it in a manner similar to the way an eRx is received from a prescriber. That manual send function (with whatever security elements the DEA would require) is absent from all pharmacy software I have seen.

 

[firework]

If the system existed, you would send the eRx from your pharmacy to another. They would receive it in a manner similar to the way an eRx is received from a prescriber. That manual send function (with whatever security elements the DEA would require) is absent from all pharmacy software I have seen.

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If that's the case, why does it say
" However, you cannot transfer a CII prescription to another pharmacy if you are unable to fill it."​

 

[Sine Cura]

Remember no legal mandate was established with this rule so no one remotely concerned about board action actually does it or cares enough about wanting CIIs from other pharmacies

 

[firework]

Remember no legal mandate was established with this rule so no one remotely concerned about board action actually does it or cares enough about wanting CIIs from other pharmacies

okay, it's all hypothetical. I'm just upset with myself that I can't understand the language they speak.

 

[Twentytwelve2]

If the regulations made any sense, where would they make money fining pharmacies? We would all be perfect

 

[zelman]

​

If that's the case, why does it say​

" However, you cannot transfer a CII prescription to another pharmacy if you are unable to fill it."​

Either because a “transfer” is a defined process done via telephone or it’s an Oklahoma law.

 

[txpharmguy]

Federal law would allow "forwarding" of unfilled ECPS. However, no national chain, to my knowledge, has this capability built into their software.