Oregon BOP's take on the DEA forwarding issue

[pharm B]

Yes, a pharmacy can transfer a new electronic prescription for controlled substance (EPCS) to another pharmacy outside of their chain. Like you mentioned, the DEA has clarified as long as both parties are registered with the DEA, forwarding, or what we traditionally call transferring, of a EPCS is allowed.

Please let me know if I can answer any more questions.

Thank you,

Jane Gin, Pharm.D, R.Ph | Pharmacy Inspector

Oregon Board of Pharmacy

800 NE Oregon Street, Suite 150

Portland OR 97232


=======
To: PHARMACY BOARD * BOP <[email protected]>
Subject: Clarification Request (Compliance and Rules)


Hey there,


For new electronic controlled prescriptions CIII-CV, can a pharmacy transfer this prescription to another pharmacy outside of their chain?


Example:


WalVS gets a new e-Rx for clonazepam and doesn’t fill it. Can they send that to a Buy Mart if it’s never been filled? DEA’s clarification only says it can be forwarded, but I haven’t seen a legal definition of “forward” in OR laws and rules, or in any document provided by the DEA.


I’d appreciate an answer in writing so that other pharmacists can review and discuss.


Thanks!

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[owlegrad]

Huh, who would have thought?

@Lnsean @wagrxm2000

 

[wagrxm2000]

Huh, who would have thought?

@Lnsean @wagrxm2000

Ha, I like how the response says yes just like it has already been clarified.

 

[Lnsean]

Huh, who would have thought?

@Lnsean @wagrxm2000

This is actually from the Oregon BOP, not the DEA. The other states, like NJ, have deferred this issue to the DEA. While I'm proud that Oregon BOP is standing up to clarifiy this, it has no bearing on the other states. Also, the issue is all unfilled controlled scripts not just electronic scripts that are unfilled. The person did a poor job of asking the question. All he had to do was ask if unfilled controlled scripts can be transferred verbally. It's not that hard, but instead he chose to narrow the BOP's answers before one was even given.

All in all, I'm still not transferring those. You're more than welcome to do so.

 

[owlegrad]

Ha, I like how the response says yes just like it has already been clarified.

That is by far my favorite part.

 

[Lnsean]

Also, on matters where state bop regulations and federal law do not agree, the stricter interpretation prevails...which in this case, is the DEA's interpretation. So honestly, it doesn't matter that Oregon BOP is telling you it's okay, they can't override a stricter DEA regulation. The person OP should be emailing is the DEA, not some lady at Oregon BOP.

 

[pharm B]

This is actually from the Oregon BOP, not the DEA. The other states, like NJ, have deferred this issue to the DEA. While I'm proud that Oregon BOP is standing up to clarifiy this, it has no bearing on the other states. Also, the issue is all unfilled controlled scripts not just electronic scripts that are unfilled. The person did a poor job of asking the question. All he had to do was ask if unfilled controlled scripts can be transferred verbally. It's not that hard, but instead he chose to narrow the BOP's answers before one was even given.

All in all, I'm still not transferring those. You're more than welcome to do so.

I thought the question was regarding e-prescriptions, which is why I phrased the initial query the way I did.

Sorry for my poor job of it. 😉

 

[owlegrad]

Also, on matters where state bop regulations and federal law do not agree, the stricter interpretation prevails...which in this case, is the DEA's interpretation. So honestly, it doesn't matter that Oregon BOP is telling you it's okay, they can't override a stricter DEA regulation.

I love that you just can't let it go. You are wrong, just accept it. The DEA has clarified that it is allowed and has always been allowed. Even this BOP is like "What's the issue? The DEA has said forwarding is fine so what's the problem?" (paraphrased)

 

[Lnsean]

I love that you just can't let it go. You are wrong, just accept it. The DEA has clarified that it is allowed and has always been allowed. Even this BOP is like "What's the issue? The DEA has said forwarding is fine so what's the problem?" (paraphrased)

Umm no. Walgreens, CVS, Walmart are telling employees to not transfer ALL UNFILLED CONTROLS, not just electronic ones. The issue is more encompassing than just electronic scripts, it includes all unfilled controlled scripts.

The DEA has clarified that it is allowed and has always been allowed. Even this BOP is like "What's the issue? " (paraphrased)

Umm no...I mean your buddy @wagrxm2000 just made a comment directly above your post sarcastically saying that DEA has not clarified this issue.

 

[Lnsean]

I love that you just can't let it go. You are wrong, just accept it. The DEA has clarified that it is allowed and has always been allowed. Even this BOP is like "What's the issue? The DEA has said forwarding is fine so what's the problem?" (paraphrased)

I have already let it go. You're the one that linked me to this post. lol. You're the one that is overly defensive about this and probably can't stop thinking about it that you had to link me back to this post because in the last thread everyone kinda told you that you were wrong.

 

[owlegrad]

I have already let it go. You're the one that linked me to this post. lol. You're the one that is overly defensive about this and probably can't stop thinking about it that you had to link me back to this post because in the last thread everyone kinda told you that you were wrong.

Hypothetically, if you were an independent pharmacy owner in Oregon (so no corporate policy applies) would you follow the BOP's guidance on this issue or would you tell them they are wrong and that the DEA in fact does not mean transferring when they say forwarding? It's ok if you don't want to play hypothetical though, I am just curious.

 

[Lnsean]

Hypothetically, if you were an independent pharmacy owner in Oregon (so no corporate policy applies) would you follow the BOP's guidance on this issue or would you tell them they are wrong and that the DEA in fact does not mean transferring when they say forwarding? It's ok if you don't want to play hypothetical though, I am just curious.

Okay, here's how we settle this. Tomorrow when you come into work and get a legitimate transfer request for an unfilled controlled script, you have to make a decision:

1. IF you choose to NOT DO THE TRANSFER, then you must accept that the request is not a legal request because the DEA does not allow such transfers.

OR

2. IF you DO THE TRANSFER, then you are accepting that it is a legal transfer and continue to take on this interpretation.

Whichever one you choose, there is NO SCENARIO where you can REJECT THE TRANSFER and also say that it's a legal request otherwise you are breaking another regulation by not complying to another pharmacy's legal request. You cannot have your cake and eat it too. This is the stance you are taking. When I asked if you were doing these transfers, you said no, but here you are arguing that it's legal, then you are breaking the other regulations that comes with a legal transfer request. If you think that it is legal, then you must comply and transfer.

For the majority of us who are working for Rite Aid, Walgreens, CVS, and Walmart, we are not transferring this, so we must accept that these are not legal requests. Until this is further clarified by someone other than Bob, Lisa, or Jen at XQZY, this is what the majority of pharmacists will do tomorrow. What you do is on you, no one cares.

And to answer your hypothetical, no. I would not do it. As soon as I realize that WAGS, CVS, and Walmart are not doing it, I would not be doing it either. I rather stick with what the industry practice is and be wrong than be the lone guy doing something that no one else is doing.

 

[owlegrad]

You cannot have your cake and eat it too.

You are the one who wants to have your cake and eat it too. You are claiming that it used to be legal to transfer controls because everyone did it but now it is illegal because nobody does it. The DEA has made it abundantly clear that it has not changed it's stance on this issue. You agree with that statement, correct?

So we have to conclude that it has either always been illegal to do so or that it continues to be legal to do so. Which is it? Has it always been illegal to do these transfers? Or did it become illegal only recently, even though the DEA says it has not changed it's policy regarding this issue? You can see that you can't have it both ways, right?


The fact that you trust corporations over a BOP pretty much says everything about this issue.

 

[wagrxm2000]

I just want to set the record straight....











I'm not buddies with that Democrat.

 

[CetiAlphaFive]

Also, on matters where state bop regulations and federal law do not agree, the stricter interpretation prevails...which in this case, is the DEA's interpretation. So honestly, it doesn't matter that Oregon BOP is telling you it's okay, they can't override a stricter DEA regulation. The person OP should be emailing is the DEA, not some lady at Oregon BOP.

Hypothetically, if you were an independent pharmacy owner in Oregon (so no corporate policy applies) would you follow the BOP's guidance on this issue or would you tell them they are wrong and that the DEA in fact does not mean transferring when they say forwarding? It's ok if you don't want to play hypothetical though, I am just curious.

No proof it to me tho.

Go in to work tomorrow and transfer one to proof it to me

 

[Charcoales]

O god not another one of these controlled transfer threads

 

[Lnsean]

You are the one who wants to have your cake and eat it too. You are claiming that it used to be legal to transfer controls because everyone did it but now it is illegal because nobody does it. The DEA has made it abundantly clear that it has not changed it's stance on this issue. You agree with that statement, correct?

So we have to conclude that it has either always been illegal to do so or that it continues to be legal to do so. Which is it? Has it always been illegal to do these transfers? Or did it become illegal only recently, even though the DEA says it has not changed it's policy regarding this issue? You can see that you can't have it both ways, right?


The fact that you trust corporations over a BOP pretty much says everything about this issue.

You're avoiding the question. If you think they're legal and are refusing to do them, them it's obvious that you're breaking BOP regulations. You yourself are not doing these transfers, but you are here telling people that it's okay to do them? Practice what you preach. Lol.



As for yours, the industry interpretation changed. So you can either follow the industry or not follow it. Go in tomorrow and do one of these transfers. Don't hedge yourself by saying that you're not doing these transfers yet still believe it is legal to do so. You're breaking more regulations by doing so. If you are not doing the transfers, then you must accept that the requests are illegal other wise you're breaking another law.


Me and most of the pharmacists in America are pretty clear on our position: we are not doing them. You are still wishy washy and seem conflicted with yourself: you are not doing them but are saying that its legal.

 

[Lnsean]

No proof it to me tho.

Go in to work tomorrow and transfer one to proof it to me

Lol. He's already said he's not doing these transfers in the other thread, but he wants people to. In other words, he's telling people to do something that he himself would not do.

 

[Charcoales]

When

You're avoiding the question. If you think they're legal and are refusing to do them, them it's obvious that you're breaking BOP regulations. You yourself are not doing these transfers, but you are here telling people that it's okay to do them? Practice what you preach. Lol.



As for yours, the industry interpretation changed. So you can either follow the industry or not follow it. Go in tomorrow and do one of these transfers. Don't hedge yourself by saying that you're not doing these transfers yet still believe it is legal to do so. You're breaking more regulations by doing so. If you are not doing the transfers, then you must accept that the requests are illegal other wise you're breaking another law.


Me and most of the pharmacists in America are pretty clear on our position: we are not doing them. You are still wishy washy and seem conflicted with yourself: you are not doing them but are saying that its legal.

When has the dea ever enforced this rule?

 

[CetiAlphaFive]

Lol. He's already said he's not doing these transfers in the other thread, but he wants people to. In other words, he's telling people to do something that he himself would not do.

I was mocking you.

 

[CetiAlphaFive]

When
When has the dea ever enforced this rule?

Basically this.
No field agent is ever going to look at transfers. Ever.

I think the reason it seemed like they didn't give a **** when we were all asking for clarification was that they don't give a ****

 

[Lnsean]

I was mocking you.

Basically this.
No field agent is ever going to look at transfers. Ever.

I think the reason it seemed like they didn't give a **** when we were all asking for clarification was that they don't give a ****

Really? So are you doing these transfers or not? Stop being wishy washy. Practice what you preach. I just want to set the record straight. There's really nothing new that we're arguing here. You either are doing the transfers or you're not.

For me and everyone at Walgreens, CVS, Rite Aid, Walmart...we're not doing the transfers.

 

[Lnsean]

When

When has the dea ever enforced this rule?

Is that a valid reason to not follow regulations? Again, that's your choice. We have people here saying one thing and doing another. They're not practicing what they preach. Owl is telling people that it's okay to transfer, but he himself is not doing these transfers.

 

[CetiAlphaFive]

Really? So are you doing these transfers? I just want to set the record straight.

For me, I am not doing the transfers.

Really? So are you doing these transfers? I just want to set the record straight.
For me, I am not doing the transfers.

"The record"
LOL.

LnSean: bird law expert

 

[Lnsean]

"The record"
LOL.

LnSean: bird law expert

That's what I thought...you can't even say for sure on a forum that you're doing these transfers? Like you were illegally transferring those controlled NY scripts. lol

So again, are you currently doing these transfers or not? Easy question. Stand behind your argument.

 

[Sine Cura]

I see this merely as a classic undetailed response from a board inspector. For me (in California at least) I would expect something more comprehensive especially since board inspectors, when they come to audit your pharmacy, are nitpicky as **** and also like to make up additional requirements like calling to verify all faxed controls that already possess all of the required elements because they "claim" the DEA said pharmacists should.

DEA obviously doesn't give a **** but your BOP might depending on how active their inspectors are

 

[Lnsean]

I see this merely as a classic undetailed response from a board inspector. For me (in California at least) I would expect something more comprehensive especially since board inspectors, when they come to audit your pharmacy, are nitpicky as **** and also like to make up additional requirements like calling to verify all faxed controls that already possess all of the required elements because they "claim" the DEA said pharmacists should.

DEA obviously doesn't give a **** but your BOP might depending on how active their inspectors are

The problem is we have people on these forums telling others to do these transfers that they themselves would not do. Malicious if anything.

 

[Sine Cura]

I mean the DEA is probably not going to scrutinize transfers but a BOP inspector would, which is funny because the pharmacy practice acts for most states have yet to be updated (or will never be updated) to address specifically transfers of e-script controls

 

[Lnsean]

The problem is we have people on these forums telling others to do these transfers that they themselves would not do. Malicious if anything.

 

[wagrxm2000]

I'm not getting involved in this again but I will say this: no pharmacist stopped transferring because they thought they couldn't. All pharmacists stopped because they were told they can't.

Every pharmacist I've called to transfer a profile has said they can't transfer those controls. When I ask if they think that's what the law says, they tell me no. People care more about keeping their job then to do something they are told they can't do. Pharmacists know the law better then corporate lawyers. We went through law class and have a clear understanding of the law. There's a reason in my nearly 18 years of being a pharmacist, this was always done and it's because it clearly states you can.

That's all I have to say and there's no point in responding to me.

 

[owlegrad]

The problem is we have people on these forums telling others to do these transfers that they themselves would not do. Malicious if anything.

You are misrepresenting what I said. Perhaps you just don't recall what I said or maybe you don't understand it. I will repeat it for your benefit though. I don't work in retail. I don't do any transfers, period. So you are correct in saying that I don't do these transfers but you are drastically misrepresenting why I don't do them.

Hypothetically, if I worked retail, I would follow my corporate policy. I would however understand that I was choosing to follow my corporate policy not the law. In FL giving a transfer is not compulsory (as far as I know) so I would not be breaking any laws if I refused to give it. If I lived in a state where giving transfers was compulsory I would be faced with having to decide between breaking the law or breaking a company policy. What choice I would make hardly matters, but I think I would choose to follow the law over the corporate policy. Maybe not though if I was afraid of losing my job over it.

And you keep saying that I am telling people what to do (do the transfer). That is called a "lie". All I have asked people to do is read what the DEA has published in the federal register and decide for themselves what it means. You know, be a professional maybe?

And you are the one being wishy-washy. Just answer the question, is it legal to transfer controls? If it is illegal, when did it become illegal? What law changed? We both know that no law changed and that it has always been legal. All that has changed is corporate policy. And you trust corporate policy more than you trust a BOP.

 

[Lnsean]

You are misrepresenting what I said. Perhaps you just don't recall what I said or maybe you don't understand it. I will repeat it for your benefit though. I don't work in retail. I don't do any transfers, period. So you are correct in saying that I don't do these transfers but you are drastically misrepresenting why I don't do them.

Hypothetically, if I worked retail, I would follow my corporate policy. I would however understand that I was choosing to follow my corporate policy not the law. In FL giving a transfer is not compulsory (as far as I know) so I would not be breaking any laws if I refused to give it. If I lived in a state where giving transfers was compulsory I would be faced with having to decide between breaking the law or breaking a company policy. What choice I would make hardly matters, but I think I would choose to follow the law over the corporate policy. Maybe not though if I was afraid of losing my job over it.

And you keep saying that I am telling people what to do (do the transfer). That is called a "lie". All I have asked people to do is read what the DEA has published in the federal register and decide for themselves what it means. You know, be a professional maybe?

And you are the one being wishy-washy. Just answer the question, is it legal to transfer controls? If it is illegal, when did it become illegal? What law changed? We both know that no law changed and that it has always been legal. All that has changed is corporate policy. And you trust corporate policy more than you trust a BOP.

Lol. I love how you hedge your arguments. Would you do these transfers or not? That's all I need to know. Let everyone know if you stand behind your argument. In the other thread, you said you would not do these transfers, then, you should not be advising people that it's okay to do them if you're not doing them yourself. Also, if you're not practicing in retail then why does your opinion on this even matter? You don't know anything here.

Hypothetically, if I worked retail, I would follow my corporate policy. I would however understand that I was choosing to follow my corporate policy not the law. In FL giving a transfer is not compulsory (as far as I know) so I would not be breaking any laws if I refused to give it. If I lived in a state where giving transfers was compulsory I would be faced with having to decide between breaking the law or breaking a company policy. What choice I would make hardly matters, but I think I would choose to follow the law over the corporate policy. Maybe not though if I was afraid of losing my job over it.

You are hedging again. Would you do the transfers or not? For me, I would not do the transfer. See how easy it was for me to give a direct answer? Now, you try it.

And you keep saying that I am telling people what to do (do the transfer). That is called a "lie". All I have asked people to do is read what the DEA has published in the federal register and decide for themselves what it means. You know, be a professional maybe?

You took what the DEA said in its handbook of regulations out of context, only quoting parts of sentences and paragraphs: the parts that agreed with you. In several occasions, you left out the part that clearly says transfers of controls are for REFILLS ONLY. This was intentional on your end and honestly, low and unprofessional. So, please do not speak of professionalism when you blatantly misquote things to prove your point.

And you are the one being wishy-washy. Just answer the question, is it legal to transfer controls? If it is illegal, when did it become illegal? What law changed? We both know that no law changed and that it has always been legal. All that has changed is corporate policy. And you trust corporate policy more than you trust a BOP.

I have already explained this several times. Laws can change based on interpretation and application, especially when the wording is not clear, which it isn't in this case. The interpretation of this law has changed, so has industry practice.


So my main point still stands, you should not be advising people to do something that you wouldn't do yourself. It is malicious.

 

[Lnsean]

I'm not getting involved in this again but I will say this: no pharmacist stopped transferring because they thought they couldn't. All pharmacists stopped because they were told they can't.

You have a source for that? I think pharmacists stopped doing them because they were told that it was illegal and agreed/accepted that because they're not going on SDN to ask phony experts on what is lawful and what is not. Owl doesn't even practice retail pharmacy and he's here giving advices...LMAO. Otherwise, you would have thousands of pharmacists complaining to the BOP and DEA that Walgreens, Rite Aid, Walmart, and CVS are forcing them to break laws when not complying with transfer requests.

Every pharmacist I've called to transfer a profile has said they can't transfer those controls. When I ask if they think that's what the law says, they tell me no.

What a coincidence, every pharmacist I've talked to has told me it's now illegal to do these transfers. They're actually using that word...illegal. See how easy that was to make up anecdotal evidence? lmao.

Pharmacists know the law better then corporate lawyers. We went through law class and have a clear understanding of the law. There's a reason in my nearly 18 years of being a pharmacist, this was always done and it's because it clearly states you can.

I didn't know you specialized in pharmacy law...lmao. Tell us where you went to law school and where you're currently practicing. Enlighten us. Just because you've been doing something for 18 years does not mean it was right.

That's all I have to say and there's no point in responding to me.

This is hysterical...we're not in high school. if you put up a response, expect people to reply to it.

 

[owlegrad]

See how easier it was for me to give a direct answer? Now, you try it.

You give a direct answer when it is convenient for you to do so. When did the law change? Why did anyone's "interpretation" change?

Why does a corporate "interpretation" trump a BOP "interpretation"? That I think is the part I don't get - why do you have more trust in corporations than you do one of the very institutions that exists to govern our profession?

And my answer is direct - I would follow the law. If my company policy violated the law I then have to choose between breaking the law or losing my job. It is hard to know for sure what I would do in that case and I think if you are being truthful you would understand that. Thankfully my employer doesn't have any policies that I know of that break the law and I don't have to decide between personal integrity and gainful employment. 🙂

 

[Lnsean]

You give a direct answer when it is convenient for you to do so. When did the law change? Why did anyone's "interpretation" change?

Why does a corporate "interpretation" trump a BOP "interpretation"? That I think is the part I don't get - why do you have more trust in corporations than you do one of the very institutions that exists to govern our profession?
🙂

Hey hey...I don't have all the answers. I know that interpretation has changed. That you cannot deny. Practice has changed. That you also cannot deny. All we're looking for is a simple clarification from the DEA. Could you help us? Maybe shoot them an email and introduce yourself as a lawyer in pharmacy practice.

And my answer is direct - I would follow the law. If my company policy violated the law I then have to choose between breaking the law or losing my job. It is hard to know for sure what I would do in that case and I think if you are being truthful you would understand that. Thankfully my employer doesn't have any policies that i know fo that break the law and I don't have to decide between personal integrity and gainful employment.

Yes or no...stop hedging or explaining away your choices. Me: I would not transfer these scripts. Now, you try it. You:......YES or NO.

 

[owlegrad]

Yes or no...stop hedging or explaining away your choices. Me: I would not transfer these scripts. Now, you try it. You:......YES or NO.

But I thought it didn't matter since I don't even work retail and therefor in your words "don't know anything here"? Although I did work retail for many years and transferred many control scripts, some even that hadn't been filed yet. I hope I don't get arrested for those years of unlawful transfers when the DEA finds out about them.

In truth I think I would transfer them. That is what everyone did legally for years and nothing in the law changed so why would I stop? But I am not the one that has to rationalize what I know to be an unlawful choice in order to keep my job, thankfully.

And all I am asking people to do is read for themselves what the DEA has said about this. Why do you find that so malicious? It's almost like you don't want highly educated professionals to be able to think for themselves. I find that scary. I think it is far more malicious to suggest that people should turn off their brain and just accept that if a corporation tells you something, it must be true.

 

[npage148]

So. Since this is all clarified have we determined what the DEA really means when it comes to partial fills vs refills in the context of 5 refills max per rx?

 

[owlegrad]

So. Since this is all clarified have we determined what the DEA really means when it comes to partial fills vs refills in the context of 5 refills max per rx?

😆

Partial fills do not count towards the 5 refills per rx. 🙂

 

[Lnsean]

In truth I think I would transfer them. That is what everyone did legally for years and nothing in the law changed so why would I stop? But I am not the one that has to rationalize what I know to be an unlawful choice in order to keep my job, thankfully.

And all I am asking people to do is read for themselves what the DEA has said about this. Why do you find that so malicious? It's almost like you don't want highly educated professionals to be able to think for themselves. I find that scary. I think it is far more malicious to suggest that people should turn off their brain and just accept that if a corporation tells you something, it must be true.

I find it malicious that when you quote the DEA you leave out certain phrases in order to prove a point. That was intentional and misleading, in an effort to be right. That is the definition of being unprofessional and disingenuous.

Me, I am arguing for the current status quo. The burden of proof is not as heavy. You are advising someone to do things against current practice, the standard for that should be higher and you should uphold yourself to that. Being wishy washy about what "forward" means and such, you don't have the authority to make any of those assumptions. What worked for you years ago may not work today because that was not the issue being debated then.

But I thought it didn't matter since I don't even work retail and therefor in your words "don't know anything here"?

It doesn't because no one here is an expert. I just wanted to see how many times it would take for you to finally take a stance and stop hedging yourself.

 

[owlegrad]

I find it malicious that when you quote the DEA you leave out certain phrases in order to prove a point. That was intentional and misleading, in an effort to be right. That is the definition of being unprofessional and disingenuous.

Me, I am arguing for the current status quo. The burden of proof is not as heavy. You are advising someone to do things against current practice, the standard for that should be higher and you should uphold yourself to that. Being wishy washy about what "forward" means and such, you don't have the authority to make any of those assumptions. What worked for you years ago may not work today because that was not the issue being debated then.



It doesn't because no one here is an expert. I just wanted to see how many times it would take for you to finally take a stance and stop hedging yourself.

Both of us quoted certain parts of the laws and regulation and DEA response. No one wants the entire controlled substance act quoted every time you try to make a point. I am sorry that you think I had some malicious intention to try to deceive people.

So should people in Oregon believe their board of pharmacy or should they believe the corporation they work for? Simple answer please. Board or corporation?

 

[Lnsean]

Both of us quoted certain parts of the laws and regulation and DEA response. No one wants the entire controlled substance act quoted every time you try to make a point. I am sorry that you think I had some malicious intention to try to deceive people.

So should people in Oregon believe their board of pharmacy or should they believe the corporation they work for? Simple answer please. Board or corporation?

Umm no, I quoted the whole paragraph and highlighted the parts that you left you. I had to do this MULTIPLE TIMES because you kept leaving out "FOR THE PURPOSE OF REFILLING." You always seem to coincidentally leave out that part when quoting the DEA and have no explanation for why the DEA would specify such a thing. The paragraph that was quoted had like 5 sentences. I've seen you type out longer novels with your posts, so length isn't an issue here.

Look, I'm sure few people are taking advice from SDN anyways...so no foul. I would love to debate this more with you but I have an exam to study for so my responses will be a bit slower.

So should people in Oregon believe their board of pharmacy or should they believe the corporation they work for? Simple answer please. Board or corporation?

They should continue to adhere to the stricter interpretation of the DEA's policy. The BOP interpretation cannot be more lax than federal regulations on the same matter. So if you believe the DEA, then the BOP interpretation is moot.

All I'm saying is, if you are advising people to go against current practice and do these transfers then you should have irrefutable evidence, not some bs email from Jane or some telephone conversation that you had with another pharmacist or that your lawyer friend who's working part time at Starbucks is telling you it's okay.

 

[CetiAlphaFive]

That's what I thought...you can't even say for sure on a forum that you're doing these transfers? Like you were illegally transferring those controlled NY scripts. lol
So again, are you currently doing these transfers or not? Easy question. Stand behind your argument.

I also sometimes don't pay State income tax

 

[Rouelle]

I also sometimes don't pay State income tax

I also rarely paid state income tax when I lived in Texas

 

[CetiAlphaFive]

I also rarely paid state income tax when I lived in Texas

Everyone, I would like to state, for the record.

I am Jimmy Hoffa

 

[Lnsean]

Everyone, I would like to state, for the record.

I am Jimmy Hoffa

You joke, but I think you're kinda skittish after admitting to illegal transferring of NY controls on the forum. I mean whatever you put on here can never really be deleted nor are you truly anonymous. So I understand why you wouldn't want to take a stance. In that case, you have no business telling people whether they should or should not do these transfers if you, yourself, can't even stand up for what you're saying.

 

[wagrxm2000]

 

[CetiAlphaFive]

You joke, but I think you're kinda skittish after admitting to illegal transferring of NY controls on the forum. I mean whatever you put on here can never really be deleted nor are you truly anonymous. So I understand why you wouldn't want to take a stance. In that case, you have no business telling people whether they should or should not do these transfers if you, yourself, can't even stand up for what you're saying.

I'd like to state, for the legal bird record that I absolutely transferred prescriptions for controls from a new York pharmacy

 

[Lnsean]

I'd like to state, for the legal bird record that I absolutely transferred prescriptions for controls from a new York pharmacy

Yes, we already know that you illegally transferred those NY scripts. I'm asking more about the transfers that you do now. Are you transferring unfilled controlled scripts out now?

 

[CetiAlphaFive]

Yes, we already know that you illegally transferred those NY scripts. I'm asking more about the transfers that you do now. Are you transferring unfilled controlled scripts out now?

Literally you right now:

https://i.imgur.com/MtRKT8e.png

 

[owlegrad]

What exam do you have?

I am also curious what other laws have changed due to interpretations changing? I’m sure there must be some examples since you claim that’s the way laws work but I can’t think of an example where interpretation changed and that changed the ‘industry standard’. Usually a law gets pasted or removed and that’s what changes the industry standard. For example HIPAA.