Personal practice opinion on early refilling partial controls

[npage148]

So this is a practice that cause issues in my area because local pharmacists are divided on how to handle this

For example. Ativan #120 1qid with 2 refills

Person asks for fill of 30 tabs on day 1 and then 30 on day 2 and 60 on day 4.

I'm in the camp they have to exhaust the 30 tabs before they can get the next 30 (7 day or so) so they can't do the above route. Others say that as long as they don't get more than 120tabs every 30 days they can partial those 120 however they want (they are ok with the above senerio). They would fill the above and them make them wait to day 30 for the first refill

Everything regarding this is ambiguous so how do you guys handle it.

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[quickpic007]

Check with pic and DM . What's better for metrics

 

[ldiot]

Why do they want it split to begin with? Ins would make them wait anyways if you did 30 pills at a time. How many people do you have paying cash for controls trying to split them lol

 

[lord999]

So this is a practice that cause issues in my area because local pharmacists are divided on how to handle this

For example. Ativan #120 1qid with 2 refills

Person asks for fill of 30 tabs on day 1 and then 30 on day 2 and 60 on day 4.

I'm in the camp they have to exhaust the 30 tabs before they can get the next 30 (7 day or so) so they can't do the above route. Others say that as long as they don't get more than 120tabs every 30 days they can partial those 120 however they want (they are ok with the above senerio). They would fill the above and them make them wait to day 30 for the first refill

Everything regarding this is ambiguous so how do you guys handle it.

Nope, those are individual refills, where the 5 refills in six months applies. Patient just burned three fills!

https://www.deadiversion.usdoj.gov/pubs/manuals/pharm2/pharm_content.htm#10
Partial Dispensing
A pharmacist may partially dispense a prescription for schedules III-V controlled substances provided that each partial filling is recorded in the same manner as a refilling, the total quantity dispensed in all partial fillings does not exceed the total quantity prescribed, and no dispensing occurs beyond six months from the date on which the prescription was issued.


"...provided that each partial filling is recorded in the same manner as a refilling..."

is the technical point that gets you dinged. Unlike C-II's where there are no refills and partial fills have to be completed in 72 hours or the script becomes terminal for the amount dispensed in 72 hours, any partial fill of a III-V counts as a refill.

Here's where the wording is ambiguous. Are you limited to the 2 fills that are written in the prescription or the 5 in 6 months? AZ says 5 in 6 months overriding provider refill intent so long as quantity limits are not exceeded, MN says 2 and done as they take the literal stance on refill writes irrespective of the quantity actually dispensed. So in your scenario, AZ would say that there are three fills remaining (original plus five = six), but MN would void the script on day 4 at that point as original and two refills (even though not for the prescribed amount was dispensed) was done.

 

[Corpseman]

Nope, those are individual refills, where the 5 refills in six months applies. Patient just burned three fills!

https://www.deadiversion.usdoj.gov/pubs/manuals/pharm2/pharm_content.htm#10
Partial Dispensing
A pharmacist may partially dispense a prescription for schedules III-V controlled substances provided that each partial filling is recorded in the same manner as a refilling, the total quantity dispensed in all partial fillings does not exceed the total quantity prescribed, and no dispensing occurs beyond six months from the date on which the prescription was issued.


"...provided that each partial filling is recorded in the same manner as a refilling..."

is the technical point that gets you dinged. Unlike C-II's where there are no refills and partial fills have to be completed in 72 hours or the script becomes terminal for the amount dispensed in 72 hours, any partial fill of a III-V counts as a refill.

Here's where the wording is ambiguous. Are you limited to the 2 fills that are written in the prescription or the 5 in 6 months? AZ says 5 in 6 months overriding provider refill intent so long as quantity limits are not exceeded, MN says 2 and done as they take the literal stance on refill writes irrespective of the quantity actually dispensed. So in your scenario, AZ would say that there are three fills remaining (original plus five = six), but MN would void the script on day 4 at that point as original and two refills (even though not for the prescribed amount was dispensed) was done.

I've personally spoken to both the executive director and compliance officer here in AZ about this very issue and both agreed that partial fills are NOT considered refills and do not count against the 5 in 6.

 

[pezdispenser]

So this is a practice that cause issues in my area because local pharmacists are divided on how to handle this

For example. Ativan #120 1qid with 2 refills

Person asks for fill of 30 tabs on day 1 and then 30 on day 2 and 60 on day 4.

I'm in the camp they have to exhaust the 30 tabs before they can get the next 30 (7 day or so) so they can't do the above route. Others say that as long as they don't get more than 120tabs every 30 days they can partial those 120 however they want (they are ok with the above senerio). They would fill the above and them make them wait to day 30 for the first refill

Everything regarding this is ambiguous so how do you guys handle it.

I'm ok with it. My reasoning is the prescriber originally allowed the patient to have on hand up to #120 tablets at a time anyway, so I see no reason to further restrict the patient to #30 with no 'early refills'. If the insurance rejects it, I would try to override it, but if the insurance still doesn't allow it, I would just inform the patient and give them the option to pay cash or wait.

 

[pezdispenser]

Nope, those are individual refills, where the 5 refills in six months applies. Patient just burned three fills!

https://www.deadiversion.usdoj.gov/pubs/manuals/pharm2/pharm_content.htm#10
Partial Dispensing
A pharmacist may partially dispense a prescription for schedules III-V controlled substances provided that each partial filling is recorded in the same manner as a refilling, the total quantity dispensed in all partial fillings does not exceed the total quantity prescribed, and no dispensing occurs beyond six months from the date on which the prescription was issued.


"...provided that each partial filling is recorded in the same manner as a refilling..."

is the technical point that gets you dinged. Unlike C-II's where there are no refills and partial fills have to be completed in 72 hours or the script becomes terminal for the amount dispensed in 72 hours, any partial fill of a III-V counts as a refill.

Here's where the wording is ambiguous. Are you limited to the 2 fills that are written in the prescription or the 5 in 6 months? AZ says 5 in 6 months overriding provider refill intent so long as quantity limits are not exceeded, MN says 2 and done as they take the literal stance on refill writes irrespective of the quantity actually dispensed. So in your scenario, AZ would say that there are three fills remaining (original plus five = six), but MN would void the script on day 4 at that point as original and two refills (even though not for the prescribed amount was dispensed) was done.

I copied and pasted out of the DEA manual in 2009 and this is what it used to say:
https://forums.studentdoctor.net/threads/ciii-civ-refills-12-fills-in-6-months.681487/#post-8905119
"The partial dispensing may not exceed the total amount authorized in the prescription order. The dispensing of all refills must be within the six month limit.

It is permissible to dispense a prescription for a quantity less than the face amount prescribed resulting in the actual number of dispensings being greater than the number of refills indicated on the prescription."

So it was even clearer back then, and I still think it is acceptable now because it still does not say in that section that the number of partial fills is limited to 5, or have anything explicitly equating a partial fill to a full refill.

 

[wagrxm2000]

I've personally spoken to both the executive director and compliance officer here in AZ about this very issue and both agreed that partial fills are NOT considered refills and do not count against the 5 in 6.

Just to help out:

https://www.deadiversion.usdoj.gov/faq/prescriptions.htm

It's like the 6th question.

Back to the original question. Unless you have a state law stating otherwise it's up to you. If you only allow a day early for refills, I would stick to that for partial fills too. If the patient complains, they can leave.

 

[npage148]

I work in a place where we have a lot of uninsured people (don't need no gov't types) and a lot of them pay cash for scripts and do it for cost spreading purposes (suboxone)

I'm the pic but for metrics it is pretty inconsequential. It causes headaches because you need to paw through and see if it's time for the next month refills or not.

It's also against our company policy because it states that the patient needs to exhaust their current on hand supply of meds. So I guess that combined with the headache of calculating fills dates is why I'm against it. I figure the consistency of always needing to exhaust your supply is a good way to go regardless.

 

[owlegrad]

Nope, those are individual refills, where the 5 refills in six months applies. Patient just burned three fills!

This is incorrect, as stated above. Or at least it is not the way it is taught at UF and not the way it is explained in the DEA Manual.

 

[ldiot]

Nope, those are individual refills, where the 5 refills in six months applies. Patient just burned three fills!

https://www.deadiversion.usdoj.gov/pubs/manuals/pharm2/pharm_content.htm#10
Partial Dispensing
A pharmacist may partially dispense a prescription for schedules III-V controlled substances provided that each partial filling is recorded in the same manner as a refilling, the total quantity dispensed in all partial fillings does not exceed the total quantity prescribed, and no dispensing occurs beyond six months from the date on which the prescription was issued.


"...provided that each partial filling is recorded in the same manner as a refilling..."

is the technical point that gets you dinged. Unlike C-II's where there are no refills and partial fills have to be completed in 72 hours or the script becomes terminal for the amount dispensed in 72 hours, any partial fill of a III-V counts as a refill.

Here's where the wording is ambiguous. Are you limited to the 2 fills that are written in the prescription or the 5 in 6 months? AZ says 5 in 6 months overriding provider refill intent so long as quantity limits are not exceeded, MN says 2 and done as they take the literal stance on refill writes irrespective of the quantity actually dispensed. So in your scenario, AZ would say that there are three fills remaining (original plus five = six), but MN would void the script on day 4 at that point as original and two refills (even though not for the prescribed amount was dispensed) was done.

The MN law is completely stupid if that actually what it means. The 5 in 6 months thing like you are describing in AZ would make a little more sense but I'm still not convinced that "recording a partial filling in the same manner as refilling" actually means that it counts as a refill for the purpose of the 5 in 6 month law. I would interpret it that as you must subtract the amount dispensed from the total quantity remaining, just as you would with a refill. In other words all it's saying is there has to be record of you dispensing the drug. By your logic even if the patient isn't getting the drug early they lose a refill, and if the pharmacy is out of stock and gives the patient 3 pills they also lose a refill. I just don't think that's the case.

Most company policies are that you shouldn't dispense until the patient has "x" days worth left in their possession anyways so even if you don't agree with Lord999's interpretation you still have a solid reason not do this and I personally wouldn't.

 

[lord999]

Just to help out:

https://www.deadiversion.usdoj.gov/faq/prescriptions.htm

It's like the 6th question.

Back to the original question. Unless you have a state law stating otherwise it's up to you. If you only allow a day early for refills, I would stick to that for partial fills too. If the patient complains, they can leave.

Thanks all for correcting me, that's a practice change. I might well call up Dean Wright (AZ western inspector, now retired) and give him a good natured ribbing for citing us for that.