Oregon BOP's take on the DEA forwarding issue

[owlegrad]

The register says nothing you are claiming. You should quote it again with a link so we all can take a look at it again. Then I will compare it to what you quoted in the other thread, side by side.

I quoted things that supposed my argument and that makes me dishonest. Interesting line of thinking. And by interesting I mean idiotic. Are you aware that truncating quotes with "..." is actually a common and generally accepted way to quote things? Did I not use "..." to indicate where I truncated a quote? Did I claim to be quoting the full text or did I make it clear I was quoting the parts I found relevant to the discussion? Honestly you just seem childish with this insistence that I am dishonest.

But if it makes you feel better call me look dishonest, by all mean, go for it. I also find it interesting that you can't debate without resorting to personal attacks. And by interesting I mean idiotic.

You are the dishonest one by the way. How many times did you misrepresent me as "telling people to do the transfers" or claiming that since I don't work retail I don't know what I am talking about? I mean it's pretty clear I have done a lot more research into this than you have. You haven't even read the relevant issue of the federal register.

I am not quoting again something that I quoted so many times to you in the other thread. I am bored with the copying and pasting. If you are not motivated to look it up yourself that is fine with me; your ability to read and understand DEA communications is not my responsibility.

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[Lnsean]

I quoted things that supposed my argument and that makes me dishonest. Interesting line of thinking. And by interesting I mean idiotic. Are you aware that truncating quotes with "..." is actually a common and generally accepted way to quote things? Did I not use "..." to indicate where I truncated a quote? Did I claim to be quoting the full text or did I make it clear I was quoting the parts I found relevant to the discussion? Honestly you just seem childish with this insistence that I am dishonest.

Truncating is okay if you didn't leave out words that totally change the meaning of what you're quoting. Yea, that's dishonest.

You are the dishonest one by the way. How many times did you misrepresent me as "telling people to do the transfers" or claiming that since I don't work retail I don't know what I am talking about? I mean it's pretty clear I have done a lot more research into this than you have. You haven't even read the relevant issue of the federal register.

Research? Oh come on, you are giving yourself way too much credit here. You copied and pasted the first thing you found...out of context to I may add. It was like child's play. All i had to do was google each of your quoted stem and found the whole source that totally contradicted the 2-3 sentences that seemed to only stick in your head.

I am not quoting again something that I quoted so many times to you in the other thread. I am bored with the copying and pasting. If you are not motivated to look it up yourself that is fine with me; your ability to read and understand DEA communications is not my responsibility.

If I were you, I wouldn't either.

 

[owlegrad]

Truncating is okay if you didn't leave out words that totally change the meaning of what you're quoting. Yea, that's dishonest.



Research? Oh come on, you are giving yourself way too much credit here. You copied and pasted the first thing you found...out of context to I may add. It was like child's play. All i had to do was google each of your quoted stem and found the whole source that totally contradicted the 2-3 sentences that seemed to only stick in your head.

Nothing you quoted contradicted what I said. The line about ‘for the purposes of refilling’ was always in the original law and it was always understood that you could transfer the original Fill. No one is contesting that.

And I never omitted the part about forwarding, you have invented that after the fact. I simply don’t find it hard to accept that forwarding and transferring mean the same thing in this context. If Forwarding meant something else the DEA would have given us guidelines for its meaning I would expect. Apparently the Oregon Board of pharmacy as well as some others agree with me.

I think the only part I ever left out were the words ‘for the purposes of refilling’ and again that was always in the original law and was never taken to mean that you couldn’t transfer the first Fill. That’s a totally new interpretation that came out of nowhere. I don’t expect you to get the historical context though since you haven’t up to this point.

And perhaps I am giving myself too much credit but I’m the one posting original sources. Which original source did you post? Oh that’s right: none, you only responded to when I posted. So yeah I think it’s fair to say I’ve done more reading on this topic then you have, since you’ve only read what I posted. Perhaps you could enhance your understanding of this issue if you actually read more than just the stems of when I posted?

 

[Rouelle]

Well this thread has taken an unpleasant turn

 

[BenJammin]

forwarding, or what we traditionally call transferring

 

[Lnsean]

And perhaps I am giving myself too much credit but I’m the one posting original sources. Which original source did you post? Oh that’s right: none, you only responded to when I posted. So yeah I think it’s fair to say I’ve done more reading on this topic then you have, since you’ve only read what I posted. Perhaps you could enhance your understanding of this issue if you actually read more than just the stems of when I posted?

Actually, if you go look at the other thread, I posted the correct quotes from the DEA handbook plus links for verification. Each time you misquoted something, I had to quote the original source and link it to you to remind you that you left out something...something important...like 3 sentences before you started conveniently truncating.

 

[owlegrad]

Well this thread has taken an unpleasant turn

Unpleasant but not unexpected. 🙂

 

[owlegrad]

Actually, if you go look at the other thread, I posted the correct quotes from the DEA handbook plus links for verification. Each time you misquoted something, I had to quote the original source and link it to you to remind you that you left out something...something important...like 3 sentences before you started conveniently truncating.

I could go back and quote three more sentinces you didn’t quote. The source material in every case is quite lengthy. Like I said no one wants the entire controlled substance act or federal register quoted.

You might have a leg to stand on saying that I was dishonest except that Oregon and other BOPs agree with me so I must not be too ‘dishonest’ in what I think are the important parts.

But I understand you can’t really argue the facts of the case anymore so now you just have to attack my character. Proceed.

Edit: I thought that I had posted links to my sources in that other thread but memories is a tricky thing, maybe I didn’t.

 

[CetiAlphaFive]

This gives you an excuse to misquote the DEA and misrepresent data? No. Like, how does that excuse you from the fact that you intentionally try to mislead them? Just because you weren't successful doesn't absolve you from the responsibility. You tried to explain that "forward" was the same as "transfer" when the DEA's language didn't fit your argument. You tried to quote certain parts of the DEA handbook and intentionally leave out parts that didn't agree. You were intentionally trying to mislead people just to win an argument.



The register says nothing you are claiming. You should quote it again with a link so we all can take a look at it again. Then I will compare it to some of the laughable "gems" you posted in the other thread.

Did you not read the stuff he posted in the last thread?

The DEA said, quote,

"requirements related to the transfer of unfilled prescriptions for controlled medications remains unchanged.
Transfer of CII-CV prescriptions is allowed on a one time basis"

What link were you reading?

 

[owlegrad]

Did you not read the stuff he posted in the last thread?

The DEA said, quote,

"requirements related to the transfer of unfilled prescriptions for controlled medications remains unchanged.
Transfer of CII-CV prescriptions is allowed on a one time basis"

What link were you reading?

My favorite part is the part about "allowing the transfer of original prescription information" but somehow even that doesn't mean what I think it means.


Of course we are being dishonest by only posting the parts that support our malicious intentions.

 

[Lnsean]

Did you not read the stuff he posted in the last thread?

The DEA said, quote,

"requirements related to the transfer of unfilled prescriptions for controlled medications remains unchanged."
Transfer of CII-CV prescriptions is allowed on a one time basis"

Except this isn't the exact quote from the DEA. Please quote your sources so I can cite directly from them. Here is the exact quote from the handbook:

"Transfer of Schedules III-V Prescription Information
A DEA registered pharmacy may transfer original prescription information for schedules III, IV, and V controlled substances to another DEA registered pharmacy for the purpose of refill dispensing between pharmacies, on a one time basis only. However, pharmacies electronically sharing a real-time, online database may transfer up to the maximum refills permitted by law and the prescriber’s authorization."

Source: SECTION IX-XIV

Again, you are misquoting the DEA. This is the sht that I am talking about.

AND here is the APha's stance on it:

"DEA has clarified for pharmacists the protocol for forwarding unfilled prescriptions for controlled substances.
DEA has clarified for pharmacists the protocol for forwarding unfilled prescriptions for controlled substances. The original e-prescription can be forwarded from one DEA-registered community pharmacy to another if they cannot fill it for any reason, according to DEA's associate section chief of the liaison and policy section of the agency's Diversion Control Center division, Loren Miller. In an email to National Association of Boards of Pharmacy CEO Carmen Catizone, Miller 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." Of the clarification, NACDS president and CEO Steve Anderson noted: "Simply put, this guidance encourages the use of electronic prescribing for controlled substances, and removes a substantial barrier to doing so. Electronic prescribing has significant advantages over other forms of transmitting a prescription because it reduces opportunities for fraud and abuse."

Source: DEA clarifies guidance on forwarding unfilled e-prescribed controlled substances

Here, forward DOES NOT MEAN verbal transfer, a point that your friend @Owlegrad had wrongly argued and insisted on. It is very clear that the word "forward" is used for electronic prescriptions only.

You both should make a public apology for doing such a shtty job in twisting the DEA's words and telling people to transfer/"forward" these scripts when they're not supposed to.

 

[Lnsean]

My favorite part is the part about "allowing the transfer of original prescription information" but somehow even that doesn't mean what I think it means.


Of course we are being dishonest by only posting the parts that support our malicious intentions.

There are BOPs that have taken this stance and do not allow these transfers (which you did not know about but are confident in your silly interpretations of DEA laws). It clearly says transferring of prescription information and not the original fill.. The malicious part isn't that you are trying to argue your point. The malicious part was that you and your butt buddy CetiAlphaFive don't personally follow your own advice but are advising people to do these transfers. This is called sabotaging people. He clearly doesn't even believe in what he is saying because he's afraid to even admit whether or not he's doing these transfers. Why is he not able to state whether he's doing these or not? Stand behind your word. That's the part that is malicious.

You guys are telling people to break the law, go against current practice...so you should present unquestionable evidence that what you're saying is true. Otherwise, you need to apologize and shut up.

 

[BenJammin]

Why are multiple state boards of pharmacy allowed to have different interpretations of a clear-as-crystal statute?

 

[Lnsean]

Why are multiple state boards of pharmacy allowed to have different interpretations of a clear-as-crystal statute?

To be clear, I don't think an email (especially one that only addressed electronic scripts) from Jane counts as an official Oregon BOP statement. Also, this shows you that interpretations are changing and you should err with the current industry practice. Telling people to do these transfers when you're not doing them yourself is not only wrong but malicious.

 

[BenJammin]

The way I read the law is that the only time you can transfer a C3, C4, or C5 if it was never filled is if it was sent electronically. If I worked in the outpatient pharmacy here that would be my SOP.

 

[zelman]

Ijust want to let everyone know I love these threads. Thank you.

 

[owlegrad]

Here, forward DOES NOT MEAN verbal transfer, a point that your friend @Owlegrad had wrongly argued and insisted on. It is very clear that the word "forward" is used for electronic prescriptions only.

How do you know it doesn't? Oregon thinks it does. Other states apparently do as well. The term forward is not defined anywhere by the DEA. If it meant forwarding electronically, you might think they would have specified that. I would presume they mean forward it however you like - usually when a law is going to limit an action the limits are specified. For some reason in general pharmacists love to make up laws and make up rules that don't exist and to me that seems to be the case here.

To sum all that up - why do you think forwarding has to be done electronically? What is your source for that?

Also I don't know how Ceti feels about it but I preferred "butt buddy" to "friend". Please continue to keep it classy like that.

 

[owlegrad]

Ijust want to let everyone know I love these threads. Thank you.

We do it all for you, sir.

Secretly I know I am not being a good moderator in these threads but I just can't stop myself. It's so refreshing to have an argument with someone who is not an obvious troll. It's downright fun to be accused of being a dishonest, malicious, democrat. I keep waiting for @pharm B to ban me...

 

[Lnsean]

How do you know it doesn't? Oregon thinks it does. Other states apparently do as well. The term forward is not defined anywhere by the DEA. If it meant forwarding electronically, you might think they would have specified that. I would presume they mean forward it however you like - usually when a law is going to limit an action the limits are specified. For some reason in general pharmacists love to make up laws and make up rules that don't exist and to me that seems to be the case here.

To sum all that up - why do you think forwarding has to be done electronically? What is your source for that?

Also I don't know how Ceti feels about it but I preferred "butt buddy" to "friend". Please continue to keep it classy like that.

This is not how it works. I am telling people not to do the transfers, which is consistent with industry practice (CVS, Walgreens, Riteaid, Walmart). It is consistent with certain BOPs as well.

YOU are telling people to go against current practice, against the law, and breaking regulations. YOUR BURDEN OF PROOF IS MUCH HIGHER THAN MINE. YOU should prove that forward means transfer AND IT SHOULD BE UNQUESTIONABLE. It should not be your feelings or inference. It should be cited with exact verbiage.

What you and your buddy are doing is sabotaging people...intentionally misleading your colleagues. YOU DON'T EVEN WORK IN RETAIL...your buddy @CetiAlphaFive can't even come out and say that he's doing these transfers himself, but he's telling everyone to do them.


This is straight from the NABP, citing DEA's clarification:

The Controlled Substances Act and its implementing regulations outline what can take place regarding prescriptions for controlled substances. In Title 21, Code of Federal Regulations, Section 1306.25 the DEA made a specific exception so that a DEA registered pharmacy can, once it has filled an original prescription for a controlled substance in Schedules III-V, transfer the original prescription information to another DEA registered pharmacy for the purpose of allowing that second pharmacy to then dispense any remaining valid refills still permitted by law and the prescriber’s authorization.

Loren T. Miller
Associate Section Chief
Liaison and Policy Section
Diversion Control
Division Drug Enforcement Administration

Source: http://www.pharmacy.ohio.gov/Documents/Pubs/Special/ControlledSubstances/Clarification on Transfer of Unfilled Controlled Substance Prescriptions.pdf

READ IT AGAIN AND AGAIN: you cannot transfer an unfilled control prescription. You can only transfer the refills. You may FORWARD the script electronically if your pharmacy is set up for it.

 

[owlegrad]

Industry practice =\= to the law. The law says they can be forwarded. Why should we assume that they have to be forwarded electronically? You are literally adding stipulations that don’t exist to the law.

I don’t have to prove that forwarding can be done by means other than electronic because there is no stipulation that has to be electronic. You might as well ask me to prove that it is legal to dispense Fentanyl patches in a plastic bag. I’ll never be able to find a DEA regulation that says that it is permissible to dispense Fentanyl patches in a plastic bag, does that mean it is illegal to do so?

 

[Lnsean]

Industry practice =\= to the law. The law says they can be forwarded. Why should we assume that they have to be forwarded electronically? You are literally adding stipulations that don’t exist to the law.

I don’t have to prove that forwarding can be done by means other than electronic because there is no stipulation that has to be electronic. You might as well ask me to prove that it is legal to dispense Fentanyl patches in a plastic bag. I’ll never be able to find a DEA regulation that says that it is permissible to dispense Fentanyl patches in a plastic bag, does that mean it is illegal to do so?

Here, let me quote you the law then. This is straight from the NABP, citing DEA's clarification:

The Controlled Substances Act and its implementing regulations outline what can take place regarding prescriptions for controlled substances. In Title 21, Code of Federal Regulations, Section 1306.25 the DEA made a specific exception so that a DEA registered pharmacy can, once it has filled an original prescription for a controlled substance in Schedules III-V, transfer the original prescription information to another DEA registered pharmacy for the purpose of allowing that second pharmacy to then dispense any remaining valid refills still permitted by law and the prescriber’s authorization.

Loren T. Miller
Associate Section Chief
Liaison and Policy Section
Diversion Control
Division Drug Enforcement Administration

Source: http://www.pharmacy.ohio.gov/Documents/Pubs/Special/ControlledSubstances/Clarification on Transfer of Unfilled Controlled Substance Prescriptions.pdf

READ IT AGAIN AND AGAIN: you cannot transfer an unfilled control prescription. You can only transfer the refills. You may FORWARD the script electronically if your pharmacy is set up for it.

 

[wagrxm2000]

Walgreens has decided not to transfer any prescriptions due to a new interpretation of the law. After announcing this, CVS and Walmart decide not to transfer any prescriptions too. The law has now changed due to "industry standard", no prescription can now be transferred.

Does this sound ridiculous? Well it should because the "industry standard" does not change laws.

As usual in this thread there is no point in responding to me.

 

[Lnsean]

Walgreens has decided not to transfer any prescriptions due to a new interpretation of the law. After announcing this, CVS and Walmart decide not to transfer any prescriptions too. The law has now changed due to "industry standard", no prescription can now be transferred.

Does this sound ridiculous? Well it should because the "industry standard" doesdoes change laws.

As usual in this thread there is no point in responding to me.

Here, let me quote you the law then. This is straight from the NABP, citing DEA's clarification:

The Controlled Substances Act and its implementing regulations outline what can take place regarding prescriptions for controlled substances. In Title 21, Code of Federal Regulations, Section 1306.25 the DEA made a specific exception so that a DEA registered pharmacy can, once it has filled an original prescription for a controlled substance in Schedules III-V, transfer the original prescription information to another DEA registered pharmacy for the purpose of allowing that second pharmacy to then dispense any remaining valid refills still permitted by law and the prescriber’s authorization.

Loren T. Miller
Associate Section Chief
Liaison and Policy Section
Diversion Control
Division Drug Enforcement Administration

Source: http://www.pharmacy.ohio.gov/Documents/Pubs/Special/ControlledSubstances/Clarification on Transfer of Unfilled Controlled Substance Prescriptions.pdf

READ IT AGAIN AND AGAIN: you cannot transfer an unfilled control prescription. You can only transfer the refills. You may FORWARD the script electronically if your pharmacy is set up for it.

 

[CetiAlphaFive]

Ijust want to let everyone know I love these threads. Thank you.

Can you proof it to me HERE that you love these threads?

 

[Lnsean]

Can you proof it to me HERE that you love these threads?

This is the guy that is telling everyone to do the transfers but he himself doesn't do them....or maybe he did a ton of them and can't admit it here.

 

[CetiAlphaFive]

This is the guy that is telling everyone to do the transfers but he himself doesn't do them....or maybe he did a ton of them and can't admit it here.

I am in my pharmacy right now on Mary Street on North Brother Island in New York City.

I'm logged in remotely to a Texas pharmacy transferring unfilled controlled prescriptions written by a New York NP.

Call the cops

EDIT:

"Maybe he did a ton of them"

LOL, you're gonna have to report a lot of people to your Bird Board of Pharmacy if you're implying previous transfers are a liability.

 

[Lnsean]

I am in my pharmacy right now on Mary Street on North Brother Island in New York City.

I'm logged in remotely to a Texas pharmacy transferring unfilled controlled prescriptions written by a New York NP.

Call the cops

Why would i do that...I love you dude. I was just curious that's all.

"Maybe he did a ton of them"

LOL, you're gonna have to report a lot of people to your Bird Board of Pharmacy if you're implying previous transfers are a liability.

Wad? I'm not you. I'm not here to sabotage people. I was telling everyone to err on the safe side and not do these transfers while you were telling everyone to do them. I just wanted to see why you would lie and spread misinformation to win an argument. The motivation behind that speaks to the character of the person.

 

[wagrxm2000]

Comments. One commenter, a large pharmacy, believed that while the NPRM addressed the transfer of prescription refill information for Schedule III, IV, and V controlled substance prescriptions, it did not address the transfer of original prescriptions that have not been filled.

DEA Response. As DEA explained in the NPRM, the existing requirements for transfers of Schedule III, IV, and V controlled substances prescriptions remain unchanged. DEA currently permits the transfer of original prescription information for a prescription in Schedules III, IV, and V on a one-time basis. This allowance does not change

 

[Lnsean]

Comments. One commenter, a large pharmacy, believed that while the NPRM addressed the transfer of prescription refill information for Schedule III, IV, and V controlled substance prescriptions, it did not address the transfer of original prescriptions that have not been filled.

DEA Response. As DEA explained in the NPRM, the existing requirements for transfers of Schedule III, IV, and V controlled substances prescriptions remain unchanged. DEA currently permits the transfer of original prescription information for a prescription in Schedules III, IV, and V on a one-time basis. This allowance does not change

Buddy, we've already discussed that. It clearly says the transfer of "prescription information" not the original fill. The DEA permits the transfer of original prescription information for the purpose of refilling. This is clearly outlined here:

"The Controlled Substances Act and its implementing regulations outline what can take place regarding prescriptions for controlled substances. In Title 21, Code of Federal Regulations, Section 1306.25 the DEA made a specific exception so that a DEA registered pharmacy can, once it has filled an original prescription for a controlled substance in Schedules III-V, transfer the original prescription information to another DEA registered pharmacy for the purpose of allowing that second pharmacy to then dispense any remaining valid refills still permitted by law and the prescriber’s authorization."

Source: http://www.pharmacy.ohio.gov/Documents/Pubs/Special/ControlledSubstances/Clarification on Transfer of Unfilled Controlled Substance Prescriptions.pdf

This is straight communication from the DEA to the NABP and also in the DEA handbook of federal regulations.

 

[CetiAlphaFive]

Comments. One commenter, a large pharmacy, believed that while the NPRM addressed the transfer of prescription refill information for Schedule III, IV, and V controlled substance prescriptions, it did not address the transfer of original prescriptions that have not been filled.

DEA Response. As DEA explained in the NPRM, the existing requirements for transfers of Schedule III, IV, and V controlled substances prescriptions remain unchanged. DEA currently permits the transfer of original prescription information for a prescription in Schedules III, IV, and V on a one-time basis. This allowance does not change

I'm pretty sure Owle and I posted that for LnSean at least 5 times in the last thread.

Get ready for some Gold Medal tier mental gymnastics as they explain away that document

 

[CetiAlphaFive]

Why would i do that...I love you dude. I was just curious that's all.
Wad? I'm not you. I'm not here to sabotage people. I was telling everyone to err on the safe side and not do these transfers while you were telling everyone to do them. I just wanted to see why you would lie and spread misinformation to win an argument. The motivation behind that speaks to the character of the person.

What if it's not illegal tho?

 

[Lnsean]

What if it's not illegal tho?

You should continue to do these transfers like you are doing now and hope that one of your scripts isn't part of some kind of drug ring. It's a good risk for you to take.

 

[Lnsean]

I'm pretty sure Owle and I posted that for LnSean at least 5 times in the last thread.

Get ready for some Gold Medal tier mental gymnastics as they explain away that document

I mean it clearly says, you can only transfer the prescription information, not the original fill. How about I quote you something even better:

"The Controlled Substances Act and its implementing regulations outline what can take place regarding prescriptions for controlled substances. In Title 21, Code of Federal Regulations, Section 1306.25 the DEA made a specific exception so that a DEA registered pharmacy can, once it has filled an original prescription for a controlled substance in Schedules III-V, transfer the original prescription information to another DEA registered pharmacy for the purpose of allowing that second pharmacy to then dispense any remaining valid refills still permitted by law and the prescriber’s authorization."

Source: http://www.pharmacy.ohio.gov/Documents/Pubs/Special/ControlledSubstances/Clarification on Transfer of Unfilled Controlled Substance Prescriptions.pdf

This is straight communication from the DEA to the NABP and also in the DEA handbook of federal regulations.

 

[wagrxm2000]

I'm pretty sure Owle and I posted that for LnSean at least 5 times in the last thread.

Get ready for some Gold Medal tier men

I just wanted to post a statement straight from the dea website stating nothing has changed you can transfer. People can interpret that statement how they want.

 

[CetiAlphaFive]

You should continue to do these transfers like you are doing now and hope that one of your scripts isn't part of some kind of drug ring. It's a good risk for you to take.

No but what if it's not tho

 

[Lnsean]

I just wanted to post a statement straight from the dea website stating nothing has changed you can transfer. People can interpret that statement how they want.

Misleading and not honest, all to win an argument.

"The Controlled Substances Act and its implementing regulations outline what can take place regarding prescriptions for controlled substances. In Title 21, Code of Federal Regulations, Section 1306.25 the DEA made a specific exception so that a DEA registered pharmacy can, once it has filled an original prescription for a controlled substance in Schedules III-V, transfer the original prescription information to another DEA registered pharmacy for the purpose of allowing that second pharmacy to then dispense any remaining valid refills still permitted by law and the prescriber’s authorization."

Source: http://www.pharmacy.ohio.gov/Documents/Pubs/Special/ControlledSubstances/Clarification on Transfer of Unfilled Controlled Substance Prescriptions.pdf

This is straight communication from the DEA to the NABP and also in the DEA handbook of federal regulations.

 

[Lnsean]

No but what if it's not tho

Bro, continue to do them. I'm not your mom. Why you asking me.

 

[CetiAlphaFive]

I just wanted to post a statement straight from the dea website stating nothing has changed you can transfer. People can interpret that statement how they want.

My homie believes in the transfiguration of prescription information into a Holy hard copy made of communion on the other end of the line when he does a regular transfer, I guess.

When it's a control, the prayer fails and it isn't blessed by Larry Merlo

 

[Charcoales]

Hey who was the exact person who decided this was the interpretation? It definitely wasn't the dea

 

[CetiAlphaFive]

Hey who was the exact person who decided this was the interpretation? It definitely wasn't the dea

Wal-Mart's director of compliance for pharmacy

 

[Charcoales]

Wal-Mart's director of compliance for pharmacy

So this person speaks on behalf of the dea??

 

[CetiAlphaFive]

So this person speaks on behalf of the dea??

Nope, they are a board member in one state, and they have friends all over the place.

 

[Charcoales]

Nope, they are a board member in one state, and they have friends all over the place.

Huh so someone not even in the dea is spreading rumors that the dea is against certain kind of transfers? How can this be?

 

[Lnsean]

Hey who was the exact person who decided this was the interpretation? It definitely wasn't the dea

Huh so someone not even in the dea is spreading rumors that the dea is against certain kind of transfers? How can this be?

LMAO, It was the DEA though:

"The Controlled Substances Act and its implementing regulations outline what can take place regarding prescriptions for controlled substances. In Title 21, Code of Federal Regulations, Section 1306.25 the DEA made a specific exception so that a DEA registered pharmacy can, once it has filled an original prescription for a controlled substance in Schedules III-V, transfer the original prescription information to another DEA registered pharmacy for the purpose of allowing that second pharmacy to then dispense any remaining valid refills still permitted by law and the prescriber’s authorization.

Loren T. Miller
Associate Section Chief
Liaison and Policy Section
Diversion Control
Division Drug Enforcement Administration"

Source: http://www.pharmacy.ohio.gov/Documents/Pubs/Special/ControlledSubstances/Clarification on Transfer of Unfilled Controlled Substance Prescriptions.pdf

 

[Lnsean]

My homie believes in the transfiguration of prescription information into a Holy hard copy made of communion on the other end of the line when he does a regular transfer, I guess.

When it's a control, the prayer fails and it isn't blessed by Larry Merlo

Huh? It's not my belief. It's the DEA's belief:

"The Controlled Substances Act and its implementing regulations outline what can take place regarding prescriptions for controlled substances. In Title 21, Code of Federal Regulations, Section 1306.25 the DEA made a specific exception so that a DEA registered pharmacy can, once it has filled an original prescription for a controlled substance in Schedules III-V, transfer the original prescription information to another DEA registered pharmacy for the purpose of allowing that second pharmacy to then dispense any remaining valid refills still permitted by law and the prescriber’s authorization.

Loren T. Miller
Associate Section Chief
Liaison and Policy Section
Diversion Control
Division Drug Enforcement Administration"

Source: http://www.pharmacy.ohio.gov/Documents/Pubs/Special/ControlledSubstances/Clarification on Transfer of Unfilled Controlled Substance Prescriptions.pdf

 

[owlegrad]

You can make that your sig if you want rather than having to quote it over and over.

Just trying to help you out!

 

[owlegrad]

And I love that an email from Loren is the definitive answer that gets quoted over and over but an email from Jane is “not an official statement” or whatever it is you said.

Yeah there is no bias there, LMAO

 

[Lnsean]

And I love that an email from Loren is the definitive answer that gets quoted over and over but an email from Jane is “not an official statement” or whatever it is you said.

Yeah there is no bias there, LMAO

Is the email from Jane from the DEA though? Could you link the email again...I must have missed that Jane works for the DEA....oh wait...she doesn't work for the DEA...and her email was in response to electronic prescriptions.

 

[Lnsean]

You can make that your sig if you want rather than having to quote it over and over.

Just trying to help you out!

What's troubling is that there seems to be few people here who have a personal stake in this argument; they have been doing these transfers illegally and are telling people to do the same. So rather than admit that they were wrong, they continue to propagate misinformation. The people that have not been doing these transfers; they're not implicated in anything nor are they putting themselves at risk for anything related to this issue, so they post their one post and off they go.

I am more disgusted at the malice that some of you guys have towards your own colleagues in trying to win an argument. There was a guy in the other thread who was threatening to report people to the BOP for refusing the transfer even though he was the one in the wrong the whole time.

Both you and @CetiAlphaFive continue to spread lies even after another poster linked you a direct clarification from the DEA. The same clarification that I have been quoting. The DEA letter clearly defines that you can only transfer refills on controls, not the original fill. This is clearly in contradiction to everything you have said. Your whole argument has been contradicted by the DEA, yet you continue to persist. That's what I don't get; there's disingenuous motivation behind this. It's not sincere, it's not honest, and it's disgusting.

 

[wagrxm2000]

Comments. One commenter, a large pharmacy, believed that while the NPRM addressed the transfer of prescription refill information for Schedule III, IV, and V controlled substance prescriptions, it did not address the transfer of original prescriptions that have not been filled.

DEA Response. As DEA explained in the NPRM, the existing requirements for transfers of Schedule III, IV, and V controlled substances prescriptions remain unchanged. DEA currently permits the transfer of original prescription information for a prescription in Schedules III, IV, and V on a one-time basis. This allowance does not change

I should make this my sig.