Stamped CII scripts

[Lnsean]

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What's Loren Miller think though? That's all that matters.

If I'm breaking the law I need to know so I can turn myself in.

I've never broken the law in the 18 years I've practiced based on my interpretation.

You do you. My problem has always been you telling other people to break the law. That's where the line is drawn.

 

[Lnsean]

Honestly? If I was a good moderator/admin I would have put a stop to this behavior a long time ago. Instead I let myself get sucked into the debate and have participated in the back and forth. What it is going to be hard for you to accept (and I don't expect you to ever accept anything I say) is that wags tagging you in a post is not stalking. The reason we have the ignore function is for that exact reason. If it bothers you, put him on ignore.

You have no reason to suspect that he has done anything besides tag you. That's it. Tagging is normal for forums. There was a poster before who honestly explained it better than I ever could but it is expected when you come to a forum that people will reference old threads and in general have fun joking about old stuff. Your response is what is not normal, not wag's.

What I should be doing is issuing warnings for name calling and closing threads that get derailed. But I have never been an excellent moderator anyway and since I have let myself become to much a part of this to stop it I am not sure what to do now. Perhaps I should recuse myself and bump it up to another admin?

He has done more than tagged me. He has followed me into other forums. If you were a true moderator, you would have been able to controlled your friends here but you're too busy being good butt buddies. Lock the thread and be over with it? Why haven't you?

 

[CetiAlphaFive]

Nah yours was a silly email...get that right..so silly it wasn't even referenced by an BoP or NABP.

No no no, mine was from the NASCSA newsletter, where Loren's boss clarified on DEA letterhead.

Wrong again

 

[Lnsean]

No no no, mine was from the NASCSA newsletter, where Loren's boss clarified on DEA letterhead.

Wrong again

Umm we went over this dude. Yours was an email and your other letter was like 10 years old. lol.

 

[wagrxm2000]

You do you. My problem has always been you telling other people to break the law. That's where the line is drawn.

Please stop stalking me, I'm having a conversation with someone else not you.

Not everything is always about you so please stop stalking me.

 

[Lnsean]

Please stop stalking me, I'm having a conversation with someone else not you.

Not everything is always about you so please stop stalking me.

Huh? You invited me into this thread. LOL

 

[owlegrad]

He has done more than tagged me. He has followed me into other forums. If you were a true moderator, you would have been able to controlled your friends here but you're too busy being good butt buddies. Lock the thread and be over with it? Why haven't you?

Haha, butt buddies. I forgot about that one. Classy.

How do you know he has followed you to other forums? A disappearing notice that could have been anyone?

Didn't I just explain why I haven't locked any threads? What specifically are you asking me to explain that I haven't already?

 

[Lnsean]

Haha, butt buddies. I forgot about that one. Classy.

How do you know he has followed you to other forums?

Didn't I just explain why I haven't locked any threads? What specifically are you asking me to explain that I haven't already?

He has followed me into the MD forums and commented on one of my posts. I got an alert..clicked on it and nothing was there. He probably deleted it...but whatever. I'm just saying that this behavior isn't normal and as moderator you're only tolerating this because they're your friends.

 

[wagrxm2000]

Huh? You invited me into this thread. LOL

Stop responding it's creepy. I invited you to answer the stamp question. Now you have this weird obsession with me.

 

[wagrxm2000]

Haha, butt buddies. I forgot about that one. Classy.

How do you know he has followed you to other forums? A disappearing notice that could have been anyone?

Didn't I just explain why I haven't locked any threads? What specifically are you asking me to explain that I haven't already?

Can you delete posts? I didn't think that was possible.

 

[CetiAlphaFive]

Umm we went over this dude. Yours was an email and your other letter was like 10 years old. lol.

Why do you insist on being wrong?

It's like you're Winnie the pooh, but you love big jars of sticky, golden wrong instead of honey.

See:

BREAK BREAK BREAK:

We interrupt your regularly scheduled ad nauseum ****posting to bring you the thrilling conclusion:

An actual, definitive answer from the DEA that addresses the "forward" wording.


http://www.nascsa.org/news/DEAtransferringUnfilledCSprescriptions10.6.17.pdf

 

[owlegrad]

Can you delete posts? I didn't think that was possible.

I can, and I thought you could as well. Is there a button between "Edit" and "Spam" marked "Delete" on the bottom left of your posts? I know for certain that donors can delete their own posts and for some reason I thought we had made it so normal users could as well, but I could be wrong about that.

 

[owlegrad]

Why do you insist on being wrong?

It's like you're Winnie the pooh, but you love big jars of sticky, golden wrong instead of honey.

See:

And let the cherry picking begin!

 

[Lnsean]

Can you delete posts? I didn't think that was possible.

Dude I know you follow my posts in the other forums.

Why do you insist on being wrong?

It's like you're Winnie the pooh, but you love big jars of sticky, golden wrong instead of honey.

See:

I mean it clearly contradicts what you're saying:

" This regulation accurately states DEA's position ~ that it is not permissible to transfer any original unfilled prescription received in paper (including fax) or oral form to another pharmacy; however, after the original prescription is filled, the refills may be transferred, subject to the conditions of 21 C.F.R. § 1306.25.

I mean you linked a document that proved that you're wrong. It clearly states that you cannot transfer unfilled controlled scripts...word for word. The original script has to be filled first and remaining refills are transferable. Not sure why this was so hard to understand.

 

[wagrxm2000]

I can, and I thought you could as well. Is there a button between "Edit" and "Spam" marked "Delete" on the bottom left of your posts? I know for certain that donors can delete their own posts and for some reason I thought we had made it so normal users could as well, but I could be wrong about that.

When did that change? I still see posts that say double post. I've done it myself somewhat recently I believe.

But yeah I see delete now.

 

[owlegrad]

When did that change? I still see posts that say double post. I've done it myself somewhat recently I believe.

But yeah I see delete now.

Don’t feel bad it actually was fairly recently.

Why are you so mad at me for proving you wrong?!?!?!

 

[wagrxm2000]

Don’t feel bad it actually was fairly recently.

Why are you so mad at me for proving you wrong?!?!?!

It's the first time I've been wrong and it's pretty infuriating.

 

[CetiAlphaFive]

Dude I know you follow my posts in the other forums.
I mean it clearly contradicts what you're saying:
" This regulation accurately states DEA's position ~ that it is not permissible to transfer any original unfilled prescription received in paper (including fax) or oral form to another pharmacy; however, after the original prescription is filled, the refills may be transferred, subject to the conditions of 21 C.F.R. § 1306.25.

I mean you linked a document that proved that you're wrong. It clearly states that you cannot transfer unfilled controlled scripts...word for word. The original script has to be filled first and remaining refills are transferable. Not sure why this was so hard to understand.

I addressed that in the same thread.

You're a glutton for w r o n g:

He [LnSean] was saying that you couldn't transfer electronic scripts (epcs) either because "forwarding" the information is not transferring.

I think only Benjammin's interpretation matches the DEA's current POLICY.


on.

 

[VA Hopeful Dr]

As much as I enjoy watching a bunch of grown-ass pharmacists bickering over this, I'm bored at work so decided to look into this myself.

So after looking at that letter from the DEA written in 2017 that @CetiAlphaFive posted. Here's my unbiased take, for what its worth.

If I as the physician send in a controlled prescription electronically, you can transfer it to another pharmacy provided it is unfilled. If you receive the prescription via verbal order or paper (whether faxed or brought in by hand from the patient), you cannot transfer that to another pharmacy unfilled. If you receive the prescription via verbal order or paper, after the initial fill you can transfer any refills to another pharmacy.

I have no idea who this makes right and who this makes wrong, but that letter seems pretty straightforward. Its recent. And its directly from the DEA.

 

[Lnsean]

I addressed that in the

You're a glutton for w r o n g:

First of all, that letter only further confirms that you cannot transfer unfilled controlled scripts. This letter reaffirms Loreen Miller's letter.

With regards to electronic prescriptions, it is obvious that forward and trasfert are two different things. You can transfer an unfilled electronic script if you and the receiving pharmacy is setup for it. It still has to abide by current laws.

All this has been discussed before...I'm not sure why you are bringing this up now. The fact is that you are not permissed to transfer unfilled controls.

 

[wagrxm2000]

As much as I enjoy watching a bunch of grown-ass pharmacists bickering over this, I'm bored at work so decided to look into this myself.

So after looking at that letter from the DEA written in 2017 that @CetiAlphaFive posted. Here's my unbiased take, for what its worth.

If I as the physician send in a controlled prescription electronically, you can transfer it to another pharmacy provided it is unfilled. If you receive the prescription via verbal order or paper (whether faxed or brought in by hand from the patient), you cannot transfer that to another pharmacy unfilled. If you receive the prescription via verbal order or paper, after the initial fill you can transfer any refills to another pharmacy.

I have no idea who this makes right and who this makes wrong, but that letter seems pretty straightforward. Its recent. And its directly from the DEA.

This is how I see it too.

It is perfectly fine to transfer an electronic control even if it's never been filled which is what I've always done.

 

[Lnsean]

This is how I see it too.

It is perfectly fine to transfer an electronic control even if it's never been filled which is what I've always done.

If you're working for Walgreens, you as hell is not transferring any unfilled controls. That's against corporate policies. So please stop lying.

 

[wagrxm2000]

If you're working for Walgreens, you as hell is not transferring any unfilled controls. That's against corporate policies. So please stop lying.

I see you're still obsessed with me.

Anyways read what was posted,it straight up says you may.

 

[Lnsean]

I see you're still obsessed with me.

Anyways read what was posted,it straight up says you may.

Nah I just like to catch you in a lie.

 

[wagrxm2000]

The DEAs current policy is you may transfer an unfilled electronic control.

That's straight from that letter.

 

[Lnsean]

The DEAs current policy is you may transfer an unfilled electronic control.

That's straight from that letter.

Sure, but your pharmacies have to be setup to receive electronic transfers. This was already discussed in details in the old thread. A poster posted all the requirements for an electronic transfer in a chart and it can only happen from computer to computer.

 

[CetiAlphaFive]

As much as I enjoy watching a bunch of grown-ass pharmacists bickering over this, I'm bored at work so decided to look into this myself.

So after looking at that letter from the DEA written in 2017 that @CetiAlphaFive posted. Here's my unbiased take, for what its worth.

If I as the physician send in a controlled prescription electronically, you can transfer it to another pharmacy provided it is unfilled. If you receive the prescription via verbal order or paper (whether faxed or brought in by hand from the patient), you cannot transfer that to another pharmacy unfilled. If you receive the prescription via verbal order or paper, after the initial fill you can transfer any refills to another pharmacy.

I have no idea who this makes right and who this makes wrong, but that letter seems pretty straightforward. Its recent. And its directly from the DEA.

This feels just like when my wife catches me eating cake and watching cartoons at 2am

Sure, but your pharmacies have to be setup to receive electronic transfers. This was already discussed in details in the old thread. A poster posted all the requirements for an electronic transfer in a chart and it can only happen from computer to computer.

James explicitly addressed this in the PDF I posted.
It does not have to be an "electronic transfer".
There is no such thing

First of all, that letter only further confirms that you cannot transfer unfilled controlled scripts. This letter reaffirms Loreen Miller's letter.

With regards to electronic prescriptions, it is obvious that forward and trasfert are two different things. You can transfer an unfilled electronic script if you and the receiving pharmacy is setup for it. It still has to abide by current laws.

All this has been discussed before...I'm not sure why you are bringing this up now. The fact is that you are not permissed to transfer unfilled controls.

You clearly never read the PDF.

 

[CetiAlphaFive]

@VA Hopeful Dr

This is what pharmacists do while you guys count your gold bars; we argue about poorly written laws

 

[VA Hopeful Dr]

@VA Hopeful Dr

This is what pharmacists do while you guys count your gold bars; we argue about poorly written laws

Doubloons, not bars

 

[PharFromNormal]

What if it’s stamped tho guys? Is there an APhA take on this? Rules will probably change when we are providers in like 4 months... no sense in arguing about this now. Has anyone seen PAtoPharm recently?

 

[Lnsean]

This feels just like when my wife catches me eating cake and watching cartoons at 2am


James explicitly addressed this in the PDF I posted.
It does not have to be an "electronic transfer".
There is no such thing



You clearly never read the PDF.

Except the original argument in the thread was not just over electronic scripts. You guys came into that thread, guns blazing, claiming that nothing has changed and there is no change in the interpretation of the DEA, business as usual. You guys were threatening to report rphs to the BoP for not doing the transfers.

YET here, you have provided a letter along with the other letter from Loren Miller that someone else provided... stating that YOU CANNOT TRANSFER unfilled controlled scripts. You guys were telling people that it was okay to do so and nothing has changed. Both of these letters showed that there has been drastic changes. The DEA NO LONGER ALLOWS the transfer of unfilled controlled scripts. This is despite all of your claims that it would mean we had been doing it all illegally since the dawn of time.

It doesn't mean that the DEA will go after you for having done it in the past, but going forward you are not allowed to do them.

Who knew that the corporate lawyers at Walgreens, CVS, Rite Aid, and Walmart would know more about the law than some wannabees on SDN.

 

[VA Hopeful Dr]

The DEA NO LONGER ALLOWS the transfer of unfilled controlled scripts.

Except that's not true at all. It doesn't allow the transfer of unfilled scripts IF VERBAL OR PAPER, but does if electronic.

 

[Lnsean]

Except that's not true at all. It doesn't allow the transfer of unfilled scripts IF VERBAL OR PAPER, but does if electronic.

Yes, but the terms of the electronic isn't a verbal transfer though.

 

[VA Hopeful Dr]

Yes, but the terms of the electronic isn't a verbal transfer though.

Not meaning to disbelieve, but where are you seeing that (honest question)?

 

[Lnsean]

Not meaning to disbelieve, but where are you seeing that (honest question)?

I will have to dig for it. It's buried in the other old thread. It's also in the DEA handbook. Basically, the transfer is allowed if the pharmacy can electronically forward the script to the other pharmacy, with the electronic signature/DEA information intact. That's why all the major chains have stopped doing verbal transfers of these.

 

[VA Hopeful Dr]

I will have to dig for it. It's buried in the other old thread. It's also in the DEA handbook. Basically, the transfer is allowed if the pharmacy can electronically forward the script to the other pharmacy, with the electronic signature/DEA information intact. That's why all the major chains have stopped doing verbal transfers of these.

I'm assuming the same system that allows you to electronically receive scripts from me would enable you to send to another pharmacy, so should be fairly easy right?

 

[Lnsean]

I'm assuming the same system that allows you to electronically receive scripts from me would enable you to send to another pharmacy, so should be fairly easy right?

It would be but I don;'t think the chains want to invest in it. To be honest, we don't get a lot of situations or requests for these. The problem with the verbal transfer is that it breaks the electronic requirement. When you are taking a verbal, you are basically hand writing the information and resubmitting it.

 

[Lnsean]

Not meaning to disbelieve, but where are you seeing that (honest question)?

"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. With one exception, such an allowance currently does not exist for the forwarding of an unfilled prescription from one DEA registered retail pharmacy so that it may be filled at another DEA registered retail pharmacy.

Prescriptions can take the form of paper (including fax), call-in, or electronic prescription for controlled substances (EPCS). The DEA has addressed the forwarding of an EPCS prescription. The DEA published information in the preamble of the notice of proposed rulemaking (NPRM) on EPCS, 73 FR 36722, and the preamble of the interim final rule (IFR) on EPCS, 75 FR 16235. Note, because this was in the preamble and not in the EPCS regulations, it represents the DEA’s policy. As posted in the preambles of the NPRM and the IFR, 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"
Loren T. Miller
Associate Section Chief
Liaison and Policy Section
Diversion Control Division
Drug Enforcement Administration


Like you said, and consistent with the DEA, there is only one exception to the rule and that if it's an electronic prescription for controlled substances (EPCS). However, the lawyers at walgreens are saying that our computer system currently cannot forward EPCS and taking a verbal or printing it out breaks the electronic requirement. All of the chains have taken this stance and it's consistent with what is written in the DEA handbook.

I think you can look up the DEA handbook and dig out that section if you want to read more on it or visit the old thread. lol.

 

[CetiAlphaFive]

Not meaning to disbelieve, but where are you seeing that (honest question)?

It doesn't exist anywhere.
It is exactly as simple as you pointed out in your first post.

This is all a sort of exercise in futility. Lnsean experiences exaggerated cognitive dissonance and it's entertaining, in a way.
They predictably start making incredible leaps and engage in near-delusional behavior to avoid being wrong despite being presented with clear evidence.

They're attempting to state that only "electronic transfers" are allowed based on this letter from 07/20/2017: http://www.pharmacy.ohio.gov/Documents/Pubs/Special/ControlledSubstances/Clarification on Transfer of Unfilled Controlled Substance Prescriptions.pdf

On 10/06/18, James Arnold wrote the following letter to address concerns raised by the letter from 07/20/17, which specifically addressed the use of "forward" and "forwarding", which has no definition or use: http://www.nascsa.org/news/DEAtransferringUnfilledCSprescriptions10.6.17.pdf
"Additionally, please note that while you referred to "forwarding" and "forward" in your letter, we have used "transfer" and "transferring" as those are the terms in the relevant DEA regulation (21 C.F.R. § 1306.25)"
He goes on to explicitly state: " Whether a prescription can be transferred from one pharmacy to another depends on the form of the prescription (paper (including facsimile), oral (call-in), or electronic) and the schedule of the controlled substance prescribed." "However, it is DEA's current policy that any unfilled EPCS for a schedule II-V controlled substance may be transferred to another pharmacy."

 

[CetiAlphaFive]

Bird Law aside, I'm curious what @VA Hopeful Dr 's take on Stamped or otherwise pre-printed CII prescriptions is.

I always wondered how physicians who use them don't stop and think "Wait a minute... why am I writing so many identical prescriptions? Could it be that something other than medical necessity is driving my prescribing habits?"

 

[owlegrad]

I always wondered how physicians who use them don't stop and think "Wait a minute... why am I writing so many identical prescriptions? Could it be that something other than medical necessity is driving my prescribing habits?"

Yes, I wonder the same thing. I recall a dentist in my old area had stamps for the post procedure meds. It was Amox and Tylenol #3 as I recall. In his case I actually applauded the efficiency inherent in using a stamp, since most of his patients are going to get the same scripts. But anyone that writes so much percocet #240 that they need a stamp to prevent writer's cramp is just nuts.

 

[johnpharm01]

Back to the ops concern. In practice, I have seen a couple of physicians use rxs where the patients name, drs signature, and quantity are hand written but the drug name, strength and sig are stamped. Usually there are t least two sigs and the dr circles the one used. I have filled these rxs without hesitation. I think beside knowing what the reg is you have to also know the intent. The dea doesn't want rubber stamped rxs because it might be cookie cutter prescribing instead of individual prescribing for individual need and also tamper resistance.

That said I would need more detail to decide whether I would fill the OPs rxs. If the whole rx is stamped and everyone gets the same rx I would call the dr and investigate it. If I wasn't given a substantial reason I would notify the dea and refuse to fill. I know of at least one dr who got disciplined for a similar issue (cookie cutter prescribing) where they would write rxs in advance and staff would write the patients name down later. Check out the deas website for actions against drs and the state bop. Heck call the dea, I have. They don't bite.

 

[VA Hopeful Dr]

Bird Law aside, I'm curious what @VA Hopeful Dr 's take on Stamped or otherwise pre-printed CII prescriptions is.

I always wondered how physicians who use them don't stop and think "Wait a minute... why am I writing so many identical prescriptions? Could it be that something other than medical necessity is driving my prescribing habits?"

Yes, I wonder the same thing. I recall a dentist in my old area had stamps for the post procedure meds. It was Amox and Tylenol #3 as I recall. In his case I actually applauded the efficiency inherent in using a stamp, since most of his patients are going to get the same scripts. But anyone that writes so much percocet #240 that they need a stamp to prevent writer's cramp is just nuts.

Depends on the doctor honestly. Lots of procedure types have done this in the pre-EMR days. So if you're getting identical stamps for post-op percocet from say the orthopedic surgeon or the oral surgeon, that doesn't seem a big deal to me.

Seeing those from the family doctor or the pain management doctor is a different story.

 

[Winged Scapula]

Depends on the doctor honestly. Lots of procedure types have done this in the pre-EMR days. So if you're getting identical stamps for post-op percocet from say the orthopedic surgeon or the oral surgeon, that doesn't seem a big deal to me.

Seeing those from the family doctor or the pain management doctor is a different story.

I don't use stamps but writing multiple prescriptions (some scheduled some not) for multiple patients per OR day, I could see how it would come in handy.

 

[JustFillIt]

Haha you guys are weirdos!

I will fill a cii that is stamped - especially if the dose and frequency are blank, and if it makes sense (a dentist that rarely prescribed it)

And if you guys are talking about transferring on hold controls - I will try not to but will in certain urgent circumstances. I flex like rubber. I am a rubber pharmacist....

 

[zelman]

If a Texas doctor writes a prescription in New York and signs it in Texas, but then flies back to New York and stamps it there, then I fill it in Hawaii on vacation, have i broken the law?

Yes. Hawaii pharmacies can’t fill controlled substance rx’s from out of state.

 

[CetiAlphaFive]

Yes. Hawaii pharmacies can’t fill controlled substance rx’s from out of state.

Lol

 

[wagrxm2000]

Called all my local doctors yesterday and asked for authority to call in prescriptions in behalf of them.

That bypasses the apparently newly interpreted law right? It's not a transfer it's a called in script.

 

[owlegrad]

Called all my local doctors yesterday and asked for authority to call in prescriptions in behalf of them.

That bypasses the apparently newly interpreted law right? It's not a transfer it's a called in script.

Except for C2s of course.

 

[wagrxm2000]

Except for C2s of course.

Alright I guess I can transfer unfilled controls now.