Oregon BOP's take on the DEA forwarding issue

[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

I should make this my sig.

Nah you should put this:

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

LOL

---

Members don't see this ad.

 

[CetiAlphaFive]

Nah you should put this:
LOL

So can we say it's fair to summarize your stance as

"Don't do transfers because 'industry standard', AKA what my DM told me, is not to.

Don't do them, even though no law has changed, and they were common place before"
?

 

[waiter]

I had this debate with an incredulous independent pharmacist who thought I was willfully refusing to perform that transfer which is prohibited by company policy.

 

[CetiAlphaFive]

I had this debate with an incredulous independent pharmacist who thought I was willfully refusing to perform that transfer which is prohibited by company policy.

They must be living with their head under a rock.

The policy I set for everyone is to receive the transfer if they'll give it, as it's only against board policy to transfer the prescription out.

If it's not transferrable, we send the MD a fax with "CHANGE IN PHARMACY" in all caps.

Easy enough.

 

[BenJammin]

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...

No I think allowing this type of discussion is what makes you a good moderator. Why shut this down?

 

[BenJammin]

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.

I would say 99% of pharmacists are set up for that. I've never ran across a pharmacy that was unable to take a transfer except for a store with a computer outage.

 

[waiter]

I would say 99% of pharmacists are set up for that. I've never ran across a pharmacy that was unable to take a transfer except for a store with a computer outage.

The verbiage also does allow for an unfilled CII to be "forwarded" and this is the same verbiage for forwarding an unfilled electronic CIII-CV. This transfer would be allowed if there were a way to actually do that.

 

[BenJammin]

The verbiage also does allow for an unfilled CII to be "forwarded" and this is the same verbiage for forwarding an unfilled electronic CIII-CV. This transfer would be allowed if there were a way to actually do that.

Do it the same way you transfer a C3, C4, C5, or legend drug. It's not rocket science. Does your state specifically state that C2s cannot be transferred? If so then it's a moot point.

 

[Lnsean]

So can we say it's fair to summarize your stance as

"Don't do transfers because 'industry standard', AKA what my DM told me, is not to.

Don't do them, even though no law has changed, and they were common place before"
?

Can't you read? This is straight from the DEA saying you are not allowed to transfer an unfilled controlled script. Another poster had also posted this for you guys.

"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

I mean its says it verbatim that you can only transfer the refills to another pharmacy after filling the original fill at your own pharmacy. This is pretty clear and direct. Why is there any debate over this? lmao...it's because some people are obsessed with winning an argument and sabotaging their own colleagues.

 

[Lnsean]

I would say 99% of pharmacists are set up for that. I've never ran across a pharmacy that was unable to take a transfer except for a store with a computer outage.

The verbiage does not allow this unless your pharmacy can electronically forward the script to another pharmacy. Forward does not mean a verbal transfer. That's why "forward" is also used to address unfilled "CIIs" which cannot obviously be verbally transferred.

 

[pharm B]

(shrug) Guess I'll just keep doing what I've been doing, and keep a copy of the email from the Oregon BOP handy for inspections.

Also, the Board is supposed to be releasing a newsletter shortly that very specifically addresses this topic. Once it's out, I'll post it here.

There's no need to respond to this.

 

[Lnsean]

Do it the same way you transfer a C3, C4, C5, or legend drug. It's not rocket science. Does your state specifically state that C2s cannot be transferred? If so then it's a moot point.

Your state BOP does not supersede the DEA rules if it has a more lax interpretation. If the DEA does not grant or explicitly say you can transfer CIIs then it doesn't matter what your state board says, you simply cannot do it. If the DEA says you can forward it electronically, then that is all you're allowed to do. Your state board can have a stricter requirement but not a more lax one. The stricter law has to apply.

 

[Lnsean]

(shrug) Guess I'll just keep doing what I've been doing, and keep a copy of the email from the Oregon BOP handy for inspections.

Also, the Board is supposed to be releasing a newsletter shortly that very specifically addresses this topic. Once it's out, I'll post it here.

There's no need to respond to this.

That email clearly says electronic prescriptions on it. I'd caution you on using that as any kind of defense. Why put yourself at risk for such a silly thing? Jane from the Oregon BOP isn't going to supersede DEA rules. If the BOP rules and DEA rules contradict on the same issue, you must follow the stricter law.

 

[CetiAlphaFive]

Can't you read? This is straight from the DEA saying you are not allowed to transfer an unfilled controlled script. Another poster had also posted this for you guys.

"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

I mean its says it verbatim that you can only transfer the refills to another pharmacy after filling the original fill at your own pharmacy. This is pretty clear and direct. Why is there any debate over this? lmao...it's because some people are obsessed with winning an argument and sabotaging their own colleagues.

Uh oh, you'd better stop writing on C-2s.

Doctor forgot the patient address?
You can't change it.

They forgot to write "twenty" next to #20?
You can't change it.

 

[Rouelle]

I have nothing to add to this discussion.

There is no need to respond to this.

 

[BenJammin]

The verbiage does not allow this unless your pharmacy can electronically forward the script to another pharmacy. Forward does not mean a verbal transfer. That's why "forward" is also used to address unfilled "CIIs" which cannot obviously be verbally transferred.

That's not true at all. Pharmacies forward prescriptions to other pharmacies all the time. The bolded and quoted information isn't reflected in any DEA statute.

 

[wagrxm2000]

If there is one thing I've learned, telling a certain someone not to respond does not work.






No one even think about responding to this.

 

[BenJammin]

(shrug) Guess I'll just keep doing what I've been doing, and keep a copy of the email from the Oregon BOP handy for inspections.

Also, the Board is supposed to be releasing a newsletter shortly that very specifically addresses this topic. Once it's out, I'll post it here.

There's no need to respond to this.

Just promise me you won't fall for this "forward doesn't mean transfer" nonsense. If it's on hold and sent electronically then you can verbally transfer the prescription and nothing in federal law says the opposite.

 

[owlegrad]

Alright a certain someone wins the night for "best new sig". You know who you are.

 

[Lnsean]

Uh oh, you'd better stop writing on C-2s.

Doctor forgot the patient address?
You can't change it.

They forgot to write "twenty" next to #20?
You can't change it.

Except this isn't true. You are doing newbie level googling dude. Come on dude lol...the DEA has long deferred this issue to the state level. This letter can be found on almost every state BOP with simple google search:

"Consequently, DEA expects that when information is missing from or needs to be changed on a schedule II controlled substance prescription, pharmacist use their professional judgement and knowledge of state and federal laws and policies to decide whether it is appropriate to make changes to that prescription."

Source: https://nabp.pharmacy/wp-content/uploads/2016/07/DEA-missing-info-schedule-2.pdf

This is what I am talking about when I say you're malicious. You're purposely in it to just win an argument at the expense of misleading your colleagues. You don't have facts left anymore, so you're scrimmaging around on Google for any silly angle you can attack with. It speaks to your immaturity. Your proper response to all of this should had been "Guys, I was wrong. Let's move on."

 

[Lnsean]

If there is one thing I've learned, telling a certain someone not to respond does not work.






No one even think about responding to this.

Because this isn't high school. You can't just cover your ears because you don't like what you're hearing. If you can't handle people responding then don't post. Pretty simple.

 

[wagrxm2000]

Not Listening Dumb And Dumber GIF - Find & Share on GIPHY

I'm too old to figure gifs out.

 

[Lnsean]

That's not true at all. Pharmacies forward prescriptions to other pharmacies all the time.

Lmao...sure if you say so. Are you saying you've been verbally transferring CII scripts out? lol...

Do it the same way you transfer a C3, C4, C5, or legend drug. It's not rocket science. Does your state specifically state that C2s cannot be transferred? If so then it's a moot point.

Yea...okay...this is the silliest thing I have heard. You're actually verablly transferring CII's out? Please don't go around telling people that this is okay. I don't even know who would want to be the receiving pharmacist.

 

[CetiAlphaFive]

Except this isn't true. You are doing newbie level googling dude. Come on dude lol...the DEA has long deferred this issue to the state level. This letter can be found on almost every state BOP with simple google search:

"Consequently, DEA expects that when information is missing from or needs to be changed on a schedule II controlled substance prescription, pharmacist use their professional judgement and knowledge of state and federal laws and policies to decide whether it is appropriate to make changes to that prescription."

Source: https://nabp.pharmacy/wp-content/uploads/2016/07/DEA-missing-info-schedule-2.pdf

This is what I am talking about when I say you're malicious. You're purposely in it to just win an argument at the expense of misleading your colleagues. You don't have facts left anymore, so you're scrimmaging around on Google for any silly angle you can attack with. It speaks to your immaturity. Your proper response to all of this should had been "Guys, I was wrong. Let's move on."

That image is from a presentation Loren T. Miller gave on Dec. 12th, 2017 in Dallas.
In other words, that's the source material for your Trump card.

Are you saying Loren is 100% infallible when discussing transfers, but has no idea what he's talking about when it's hard copies?

 

[Lnsean]

That image is from a presentation Loren T. Miller gave on Dec. 12th, 2017 in Dallas.
In other words, that's the source material for your Trump card.

Are you saying Loren is 100% infallible when discussing transfers, but has no idea what he's talking about when it's hard copies?

Except she posted a legal disclaimer on the first 2 slides stating that her presentation does not purport to clarify or establish any DEA laws or standards. So yea, I think you are being super shady and sht by conventiently leaving out certain slides. Like, who the hell cites presentations and why would you not link the entire deck if you were gonna use that as your source.

Here is the entire slide deck:

https://www.deadiversion.usdoj.gov/mtgs/drug_chemical/2017/miller1.pdf

This is the kind of twisting and misquoting that I am talking about that you are doing to try to win an argument. Face it, you've lost on both issues in terms of fact. Trying to misquote things is shady af and dishonest. The proper and mature response for you would have been to say "I was wrong, let's move on."

Here, you've taken the extra step to misquote Loren out of context and trying to defame her. You're worst than that guy above you who was telling people to transfer CIIs like they were C3-C5s. lol. He's the same guy in the other thread that was threatening to report people to BOP for refusing the transfer even though he was wrong. Both of you guys are malicious and conniving amateurs trying everything you can to win arguments rather than be helpful to your colleagues.

Here is the slide you left out:

 

[BenJammin]

Lmao...sure if you say so. Are you saying you've been verbally transferring CII scripts out? lol...



Yea...okay...this is the silliest thing I have heard. You're actually verablly transferring CII's out? Please don't go around telling people that this is okay. I don't even know who would want to be the receiving pharmacist.

Texas doesn't allow C2s to be transferred. What are you going on about?

 

[wagrxm2000]

I few days ago I said a tech would be a pain working with. Lnsean would be even worse. He can't even tell that at this point people are just screwing with him.

And there's no point.....oh you know the rest.

 

[CetiAlphaFive]

Except she posted a legal disclaimer on the first 2 slides stating that her presentation does not purport to clarify or establish any DEA laws or standards. So yea, I think you are being super shady and sht by conventiently leaving out certain slides. Like, who the hell cites presentations and why would you not link the entire deck if you were gonna use that as your source.

Here is the entire slide deck:

https://www.deadiversion.usdoj.gov/mtgs/drug_chemical/2017/miller1.pdf

This is the kind of twisting and misquoting that I am talking about that you are doing to try to win an argument. Face it, you've lost on both issues in terms of fact. Trying to misquote things is shady af and dishonest. The proper and mature response for you would have been to say "I was wrong, let's move on."

Here, you've taken the extra step to misquote Loren out of context and trying to defame her. You're worst than that guy above you who was telling people to transfer CIIs like they were C3-C5s. lol. He's the same guy in the other thread that was threatening to report people to BOP for refusing the transfer even though he was wrong. Both of you guys are malicious and conniving amateurs trying everything you can to win arguments rather than be helpful to your colleagues.
Here is the slide you left out:

I found a photo of you

 

[Lnsean]

I few days ago I said a tech would be a pain working with. Lnsean would be even worse. He can't even tell that at this point people are just screwing with him.

And there's no point.....oh you know the rest.

I mean...if you can't stand behind your own posts then why even post? lol

 

[Lnsean]

I found a photo of you

Yea, Loren had the foresight during that presentation to include that disclaimer. She knew that 3 months later you would use this against her, the DEA, and me. The legal disclaimer is to prevent amateurs from misquoting her presentation and taking it out of context; someone with integrity would not do this. I don't know how long ago you graduated, but quoting presentations would have gotten you laughed at now, let alone parts and pieces of one that fits your agenda.

 

[owlegrad]

I am just curious, how it is out of context?

In what context would you accept the statement "current DEA regulations do not allow for changes to a written schedule II prescription"? (Apologies if I left out any critical words in that quote)

 

[wagrxm2000]

I am just curious, how it is out of context?

In what context would you accept the statement "current DEA regulations do not allow for changes to a written schedule II prescription"? (Apologies if I left out any critical words in that quote)

Whoa there, you're telling me now I can't change anything on a C2? My world is being flipped upside down. I don't know if I should believe anything that woman says. She doesn't seem to know the law very well. One would think if they are giving a power point presentation, they would know the law. Right????

 

[owlegrad]

^I want to respond to this but I will follow the directions and resist the urge.

Resisting...
Resisting......
Resisting..........

Dang it I couldn't resist!

 

[wagrxm2000]

^I want to respond to this but I will follow the directions and resist the urge.

Resisting...
Resisting......
Resisting..........

Dang it I couldn't resist!

I don't see a signature, where does it show?

 

[owlegrad]

I don't see a signature, where does it show?

Doesn't show on mobile but it does on a computer.

 

[wagrxm2000]

Doesn't show on mobile but it does on a computer.

How do I put it under my name like yours says uncontrollable sarcasm machine.

I imagine most people use their phone on here.

 

[owlegrad]

How do I put it under my name like yours says uncontrollable sarcasm machine.

I imagine most people use their phone on here.

Yeah, some huge percent of our traffic is mobile. I don't recall the break down but it is quite large. Which is a shame because I have some killer links in my sig which I suspect most people never even see.

Somewhere you can edit the "custom title" of your profile I think, but it was easier for me just to do it than it is to explain.

In the words of The Rock:

 

[CetiAlphaFive]

Yea, Loren had the foresight during that presentation to include that disclaimer. She knew that 3 months later you would use this against her, the DEA, and me. The legal disclaimer is to prevent amateurs from misquoting her presentation and taking it out of context; someone with integrity would not do this. I don't know how long ago you graduated, but quoting presentations would have gotten you laughed at now, let alone parts and pieces of one that fits your agenda.

The point of my claim is that your arguments are entirely fluid and contradictory.

Of course I know we can edit C2s.
Loren's statement clearly contradicts that.

What you need to understand is that alphabet agencies are like that.
They're DMVs with legislative power.

I could literally find a golden DEA tome found on a mountain top by the head off the DEA that was inscribed by god with "these transfers are ok yo", and you'd still find a way to dispute it.

Lol

 

[Lnsean]

Of course I know we can edit C2s.

Of course, you were just salty af about this whole debate, so you decided to take bits and pieces of Loren's presentation on a completely different issue to defame her integrity on our current issue being debated. There was no way for you to defend yourself against Loren's letter response to the NABP, stating that the DEA does not allow the transfer of unfilled controls, so you're trying to attack her now.

Loren's statement clearly contradicts that.

So? What does her presentation on changes to CII prescriptions have to do anything with what were debating? Oh right, you're personally attacking her integrity...I see...even after she has explicitly told you that what's in her presentation does not establish legal standards. Maybe someone here should email her / DEA and cite your claim and ask her why she did that...otherwise you don't know why she did that.

What you need to understand is that alphabet agencies are like that.
They're DMVs with legislative power.

I could literally find a golden DEA tome found on a mountain top by the head off the DEA that was inscribed by god with "these transfers are ok yo", and you'd still find a way to dispute it.

Lol

What you need to understand is that, unless you have unquestionable evidence, you should not be telling people to break laws or regulations. You should not be making dubious claims, inferences on matters of law; you don't have the authority to do any of this. You got caught misquoting the DEA, misquoting a presentation in an effort to defame the presenter and her integrity on an unrelated issue....just so you could win an argument. What does her presentation on changes in CII prescription have to do anything with our debate on transferring unfilled controlled scripts? You are merely attacking her character/integrity at this point.

Look, if you're going after Loren's character and integrity then you should find someone else to debate that. Make another thread and talk it over with your buddies. I don't want to be involved in any of these immature, low-ball, unprofessional and shady af tactics.

 

[wagrxm2000]

Hmm Loren is right about one thing but wrong on the other.

(See signature)

 

[Lnsean]

I am just curious, how it is out of context?

In what context would you accept the statement "current DEA regulations do not allow for changes to a written schedule II prescription"? (Apologies if I left out any critical words in that quote)

"Statements in this presentation that are not embodied in law are not binding to the DEA." Per the legal disclaimer that Loren had on slide 2 that your buddy conveniently left out. So can you find me the DEA law that forbids changes to CII prescpriptions? I would like link to the sources. I mean this has nothing to do with our current debate on unfilled controls, but I'll play ball with you guys.

 

[owlegrad]

"Statements in this presentation that are not embodied in law are not binding to the DEA." Per the legal disclaimer that Loren had on slide 2 that your buddy conveniently left out. So can you find me the DEA law that forbids changes to CII prescpriptions? I would like link to the sources. I mean this has nothing to do with our current debate on unfilled controls, but I'll play ball with you guys.

So because there is a legal disclaimer at the start of the presentation the comments in the presentation are taken out of context?

Do you know what context means?

I actually have no opinion whatsoever to changes to a C2. It has been a long time since I have researched that issue and I would need to research before I knew I recalled the finer points correctly. I just want to know how is quoting the content of a slide, without quoting a legal disclaimer from a different slide, taking said slide out of context?

I don't think you know what context is.

 

[Lnsean]

So because there is a legal disclaimer at the start of the presentation the comments in the presentation are taken out of context?

Do you know what context means?

I actually have no opinion whatsoever to changes to a C2. It has been a long time since I have researched that issue and I would need to research before I knew I recalled the finer points correctly. I just want to know how is quoting the content of a slide, without quoting a legal disclaimer from a different slide, taking said slide out of context?

I don't think you know what context is.

Yea, out of context means you took 2-3 slides that fit your argument and fail to link the deck or the disclaimer. Because the disclaimer changes the legality of what is said in the presentation. Your buddy is trying to say that changing CII is illegal because of this presentation. Look above for his post.

Here's your buddy using 2-3 slides from Loren's presentation to state that it's illegal to change CII information:

Uh oh, you'd better stop writing on C-2s.

Doctor forgot the patient address?
You can't change it.

They forgot to write "twenty" next to #20?
You can't change it.

Yep...this is the type of person you're associating yourself with. lol.

 

[owlegrad]

Yea, out of context means you took 2-3 slides that fit your argument and fail to link the deck or the disclaimer. Because the disclaimer changes the legality of what is said in the presentation. Your buddy is trying to say that changing CII is illegal because of this presentation. Look above for his post.

Here's your buddy using Loren's presentation to state that it's illegal to change CII information:

Ah so it's not the you don't understand context, it's that you didn't understand my butt buddy's point. That makes more sense.

His point is that Loren doesn't know or understand the law herself, as demonstrated by her statement about written C2 scripts. If you think he was actually arguing that no element of a written C2 may be altered, I think you missed some critical sarcasm/irony in his post.

 

[Lnsean]

Ah so it's not the you don't understand context, it's that you didn't understand my butt buddy's point. That makes more sense.

His point is that Loren doesn't know or understand the law herself, as demonstrated by her statement about written C2 scripts. If you think he was actually arguing that no element of a written C2 may be altered, I think you missed some critical sarcasm/irony in his post.

So he's attacking her personally on one issue to discredit something else that she wrote on another issue...gotcha. I just wanted to clarify that. Thank you.

 

[owlegrad]

So he's attacking her personally on one issue to discredit something else that she wrote on another issue...gotcha. I just wanted to clarify that. Thank you.

You would never attack anyone's character like that, would you?

 

[Lnsean]

You would never attack anyone's character like that, would you?

Not when that person is not here to defend herself. So please let's not stoop to his level. I don't want people to think that his opinion matters in asserting Loren's character when she's not here to defend herself. Like, he's a nobody right? He told me he makes more than me and has a really good schedule...so I'm afraid he might think he's a somebody now.

 

[owlegrad]

Not when that person is not here to defend herself. So please let's not stoop to his level. I don't want people to think that his opinion matters in asserting Loren's character when she's not here to defend herself. Like, he's a nobody right? He told me he makes more than me and has a really good schedule...so I'm afraid he might think he's a somebody now.

You seem to be doing a good job defending her honor though.

Also he never attached her personality or character. Just her credibility on issues of fact pertaining to matters involving the CSA. If she doesn't know the law concerning making changes to a C2 why should we trust that she knows what she is talking about in regards to transfers?

 

[wagrxm2000]

You seem to be doing a good job defending her honor though.

Also he never attached her personality or character. Just her credibility on issues of fact pertaining to matters involving the CSA. If she doesn't know the law concerning making changes to a C2 why should we trust that she knows what she is talking about in regards to transfers?

Bingo if you think what she says i's correct everything she says has to be correct or you can't trust anything she says

 

[Lnsean]

Also he never attached her personality or character. Just her credibility on issues of fact pertaining to matters involving the CSA. If she doesn't know the law concerning making changes to a C2 why should we trust that she knows what she is talking about in regards to transfers?

How do you know that? What if she was stating her opinion in that presentation. Do you have the recording that I can listen to? She has already said that these statements are not reflective of the DEA's stance if there is a discrepancy. You guys don't know what was said or what her intentions are...so to attack her credibility/character is kinda...shameless.

But let's be real about this, her presentation on CII changes has nothing to do with her letter to the NABP. If state BOPs are citing her letter as a reason to not allow these transfers then there is legal basis here.

This tactic or scheme that he is using to win arguments, that is not how anyone should do it and I"m sure it is not how you do it either. I have seen your posts in other threads; which is why I don't get why you are supporting this kind of behavior. It's childish and immature. I know he's your friend but it's also a reflection on you.

IF he wants to continue debating unfilled scripts, I'm all for it...but the silly games on Loren's credibility and character...you guys can debate that among yourself in another thread.