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Statin

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What are the laws regarding having multiple controls on the same prescription? Whether it be two or more schedule II controlled substances or two schedule III - V on the same prescription sheet or a mix of both C II-C V? I tried doing some googling but couldn't narrow down my search but couldn't find much. At work the other day a pharmacist refused to fill a prescription that had Adderall 10 mg and Adderall 30 mg written on the same prescription stating that they have to be two separate prescription sheets. Can anyone clarify?
 

jballer91

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In Illinois multiple orders can be on the same prescription sheet, regardless of schedule.
 

zelman

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I had a NJ pharmacist make the same claim some years ago. It was not true there either. Just convention.
 
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BidingMyTime

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I'm fairly confident that multiple C's can be on the same sheet, the exception is that C II's have to be separate from other RX's. There shouldn't be any problem with 2 CII's on the same sheet. If a doctor puts a non-CII on the same RX as a CII, then technically that would have to be copied off and verified like a phone order.
 

Statin

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In Illinois multiple orders can be on the same prescription sheet, regardless of schedule.

Do you have a source for this claim? I just want to be able to refute the pharmacists claim (for the greater good) and also it's beneficial for me to know that in fact it is okay to have multiple C's on one prescription sheet.


I'm fairly confident that multiple C's can be on the same sheet, the exception is that C II's have to be separate from other RX's. There shouldn't be any problem with 2 CII's on the same sheet. If a doctor puts a non-CII on the same RX as a CII, then technically that would have to be copied off and verified like a phone order.

That's rather odd that you can have multiple C's on the same sheet but god forbid you have a C II with a non-control rx. I've seen the latter happen multiple times and I don't recall any pharmacists in Illinois having an issue with it.
 

owlegrad

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Federal law is that you cannot mix medications of different schedules on the same Prescription. There is no limit to the number of medications in the same schedule that can be written on the same prescription.

It is so rare to see two C2s written on the same prescription that some pharmacist think it's illegal. And then of course there's state law to consider.

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zelman

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Federal law is that you cannot mix medications of different schedules on the same Prescription. There is no limit to the number of medications in the same schedule that can be written on the same prescription.
source?
 

owlegrad

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Like any good statement concerning the law this is strictly from memory of law class and information passed on from preceptor to student since the beginning of time. I can google it if you like though.
 
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zelman

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Like any good statement concerning the law this is strictly from memory of law class and information passed on from preceptor to student since the beginning of time. I can google it if you like though.
I'm pretty sure federal law says nothing about this.
 
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owlegrad

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I'm pretty sure federal law says nothing about this.

DEA website does have this in a guidance document:

"Schedule II controlled substances require a written prescription which must be manually signed by the practitioner or an electronic prescription that meets all DEA requirements for electronic prescriptions for controlled substances. There is no federal time limit within which a schedule II prescription must be filled after being signed by the practitioner. However, the pharmacist must determine that the prescription is still needed by the patient. While some states and many insurance carriers limit the quantity of controlled substances dispensed to a 30-day supply, there are no express federal limits with respect to the quantities of drugs dispensed via a prescription. However, the amount dispensed must be consistent with the requirement that a prescription for a controlled substance be issued only for a legitimate medical purpose by a practitioner acting in the usual course of professional practice. For a schedule II controlled substance, an oral order is only permitted in an emergency situation"

Which I thought was interesting since people always seem to think that 30 days is the max. I wish I could link to it directly, lol.

I couldn't find the bit about not mixing schedules on the same blank. Either it is Florida thing or I am straight up wrong.
 

jballer91

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Do you have a source for this claim? I just want to be able to refute the pharmacists claim (for the greater good) and also it's beneficial for me to know that in fact it is okay to have multiple C's on one prescription sheet.

Unfortunately not. However, I just recently had my law review class and this was one of the questions that came up and the instructor clearly said you can have as many prescriptions on one piece of paper as you want. Also, I've seen multiple C-IIs filled from the same sheet in practice (ex: a kid on multiple strengths of Adderall)


DEA website does have this in a guidance document:

"Schedule II controlled substances require a written prescription which must be manually signed by the practitioner or an electronic prescription that meets all DEA requirements for electronic prescriptions for controlled substances. There is no federal time limit within which a schedule II prescription must be filled after being signed by the practitioner. However, the pharmacist must determine that the prescription is still needed by the patient. While some states and many insurance carriers limit the quantity of controlled substances dispensed to a 30-day supply, there are no express federal limits with respect to the quantities of drugs dispensed via a prescription. However, the amount dispensed must be consistent with the requirement that a prescription for a controlled substance be issued only for a legitimate medical purpose by a practitioner acting in the usual course of professional practice. For a schedule II controlled substance, an oral order is only permitted in an emergency situation"

Which I thought was interesting since people always seem to think that 30 days is the max. I wish I could link to it directly, lol.

I couldn't find the bit about not mixing schedules on the same blank. Either it is Florida thing or I am straight up wrong.

Yeah I'm not aware of any federal or IL rules clearly stating c2/non-control is not allowed. And yeah no federal law about max days supply for c-2 but some states (including Illinois) have a max of 30 days but you are allowed to write multiple scripts and have a "do not fill until ____" for up to 3 months at once and give that to the patient
 

zelman

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... And yeah no federal law about max days supply for c-2 but some states (including Illinois) have a max of 30 days but you are allowed to write multiple scripts and have a "do not fill until ____" for up to 3 months at once and give that to the patient
Massachusetts allows 60 days on CII stimulant meds with a diagnosis that meets criteria (minimal brain dysfunction or narcolepsy) and NY allows 90 days on CII's with a "condition code*" on the Rx.

*Condition codes are some garbage the state made up as follows:
A Panic disorder
B Attention deficit disorder
C Chronic debilitating neurological conditions characterized as a movement disorder or exhibiting seizure, convulsive or spasm activity
D Relief of pain in patients suffering from conditions or diseases known to be chronic or incurable
E Narcolepsy
F Hormone deficiency states in males; gynecologic conditions that are responsive with anabolic steroids or chorionic gonadotropin; metastatic breast cancer in women; anemia and angioedema
 

Statin

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Unfortunately not. However, I just recently had my law review class and this was one of the questions that came up and the instructor clearly said you can have as many prescriptions on one piece of paper as you want. Also, I've seen multiple C-IIs filled from the same sheet in practice (ex: a kid on multiple strengths of Adderall)

I have seen multiple C-II's on the same sheet filled before as well, hence why I was puzzled. It is what it is though, the poor patient had the run around to get a new script written by the doc.
 

BidingMyTime

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Yeah I'm not aware of any federal or IL rules clearly stating c2/non-control is not allowed.

Maybe that requirement was done away with, when IL did away with triplicates for CII's.

I did come across this site, although the information appears to be dated (in the IL section, I know the part about CII's not be allowed to be filled more than 7 days after written is no longer true), so possible the 1 controlled prescription on a blank is also no longer true.

http://www.aafp.org/fpm/2011/1100/fpm20111100p16-rt1.pdf

10) Contain only one Schedule II drug prescription order per prescription blank;
12) Allow more than one prescription order per prescription blank for a Schedule III, IV or V drug.
 

zelman

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Maybe that requirement was done away with, when IL did away with triplicates for CII's.

I did come across this site, although the information appears to be dated (in the IL section, I know the part about CII's not be allowed to be filled more than 7 days after written is no longer true), so possible the 1 controlled prescription on a blank is also no longer true.

http://www.aafp.org/fpm/2011/1100/fpm20111100p16-rt1.pdf

10) Contain only one Schedule II drug prescription order per prescription blank;
12) Allow more than one prescription order per prescription blank for a Schedule III, IV or V drug.
That document does cite specific laws/regs. Anyone care to check if they've changed?
 

M0df

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Where I work now, we fill multiple CIIs on the same sheet all the time. I don't recall seeing CII and non CII on the same sheet. So it is not an issue in my state, and obviously with stricter law taking precedence, there is no federal restriction. I received a call from a doc once though. His patient took a script with 2 CIIs on it to a different state, which might have been IL, and they would not fill it.
 

Sine Cura

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There is no federal regulation on mixing schedules. Some states even state a single CII must be by itself on the blank, no other drugs, so in those cases the whole script is rendered invalid if you see a CII + other junk. (No I will not be "canceling" the non-CIIs on the script and taking oral orders.)
 

Statin

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Maybe that requirement was done away with, when IL did away with triplicates for CII's.

I did come across this site, although the information appears to be dated (in the IL section, I know the part about CII's not be allowed to be filled more than 7 days after written is no longer true), so possible the 1 controlled prescription on a blank is also no longer true.

http://www.aafp.org/fpm/2011/1100/fpm20111100p16-rt1.pdf

10) Contain only one Schedule II drug prescription order per prescription blank;
12) Allow more than one prescription order per prescription blank for a Schedule III, IV or V drug.

Can anyone find an updated link of state-by-state rules and regulations?
 
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