That's your call. The point is to not be on here telling people that nothing will happen to them going 70mph.
Walgreens in AZ refusing to xfer CIV before first fill?
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That's your call. The point is to not be on here telling people that nothing will happen to them going 70mph.
I think you went well beyond quoting. You inferred that "forward" means "transfer" and that "original prescription information" to mean it's okay to transfer the original fill.
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So if it's illegal for a pharmacist licensed in New York to transfer a prescription, and they give a transfer to a pharmacist licensed in Texas but not New York, is the pharmacist in Texas in trouble?
What if the pharmacist in a Texas pharmacy who is licensed in NY and TX?
owlegrad
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What else can forward mean? There is literally no other definition in the pharmacy world. If it means something else, perhaps the DEA should say so.
The "original prescription information" is their response to being asked if unfilled controls can be transferred. So..yeah. What else can it possibly mean? Your mental gymnastics are exhausting.
And even if you disagree, I still quoted my source. So the info is right there to be read. It's not like I made claims and provided no source for that claim.
Why not come out and say that forward means transfer then? Why used a different word? Why is the sky blue? You have so many questions but you are okay with making this interpretation. I mean tons of people have already asked for clarification after this commentary and yet...still nothing.
When I think of forward...I think of it like an email...electronically forwarded--the original eRx....not a verbal transfer.
Quoting a source doesn't give you the right to misrepresent what it means. You think just by quoting something you can twist it into whatever you want and this gives you an out? No. I don't have a problem with you quoting the commentary. I have a problem with you inferring things that were not said or extrapolating.
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I do have a lot of questions. Not really about the control transfer issue (I settled that in my mind by reading the Federal register and the comments therein) or the sky being blue (I actually think we have that one nailed down, unless you mean it in a philosophical way), but lots of questions. How is Trump president? Why do people hate other people for reasons like race, sexual orientation, and religion? Why do some people ignore facts?
Why is Ryan Seacrest so successful? Seriously, what does he do that is so special?
you should look that up. I'm not doing your dirty work for you...lmao. it's not my job to figure out your situation. maybe you should lawyer up now that there's record of you online admitting to transferring these. maybe you should call Saul.
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He would need a lawyer to look that up. A real one. Pharmacists aren't capable of interpreting laws themselves.
Also I think the question was rhetorical, although I don't want to put words in his mouth.
Maybe Saul?
Nah, never assume a question is rhetorical. Stupidity knows no bounds.
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/thread
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Local geography applies. That's part of the federal Interstate Commerce issue. The very few times I've seen it come up, it's always decided on the geographical basis unless there it's fraud specifically meant to screw the rules.
I'm supposed to be ashamed to admit that I was the pharmacist in AZ that got in trouble with the Board for telling an underaged patient across state lines to have her Plan B filled in California because they did not have a reporting requirement at the time for her age, but AZ had a mandatory one (which she did successfully, I got in trouble because she used insurance and the claim reimbursement came back in January). Couldn't even get the moral turpitude charge to stick as I was willing to contest it in the AZ ALJ as the statute would be an interstate problem for them. I figure that since my priest definitely believes that I am going to burn in hell for a mortal sin for consciously doing this, I might as well make it do some good for someone.
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How is this still going, the dea answered the question and said yes you can.
Sorry, they didn't. YOU may think they did though.
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Is this sarcasm? They did, I read the response.
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Just do what Corp overseers want while eventually a class action suit arises and everyone who blindly followed Corp gets added to the suit since you refused to use appropriate professional judgement and were complicit in delaying patient meds, coersing md offices with flippant requests for new controlled rxs to be sent based on faulty logic, and contributing to proliferation of controlled rxs (i wouldnt doubt many of the old controlled rx s aren't even close after new one is forced to be made) even after dea clarified it was ok to use the simply existing one-time txfer rule for unfilled
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Ah, you're the only that got that response then. Could you share with all of us.
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When a commenter said they didn't address if an original prescription never filled could be transferred, the response was the dea permits the transfer of the original prescription.
it does not say that though...they just responded by referring back to current regulations. i mean this where everyone has an issue.
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You clearly must be trolling. This is exactly what it says.
No it doesn't. Lmao. quote it. I mean you think everyone has a conspiracy against the DEA by questioning this?
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I did quote it, the dea permits the transfer of the original prescription. That was the response to the question regarding transferring the original unfilled prescription.
Thread closed
(my wife gets a big kick out of these)Where did you quote it? Link me please?
Thread closed
What? just your wife? My whole family is watching. It's very nerve wrecking and i have performance anxiety.
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"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. "
See that doesn't say what you claims it says. The DEA defers this back to current regulations where transfers can only be done for the purpose of refill dispensing...not the original fill. The transfer of the original prescription information does not equal the transfer of the original fill.
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So you're telling me the terms prescription refill information and original prescription information are the same thing? If you think that's true that's fine, that's your interpretation.
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.
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The word transfer implies that it has the capacity to be filled since that is the purpose of transferring therefore transferring original rx info includes the possibility of filling it
How about you stop implying. I mean the DEA has been asked repeatedly to clarify this and they have not...which is the most troubling part. That's why everyone is erring on the stricter interpretation.
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Any numbnut would know though that the sole reason an rx would be transferred is to be filled...
of course not...the wording implies that they are not. just like using "forward" instead of "transfer." you are implying that they are the same, others are not doing that. the DEA has been asked repeatedly after this commentary to clarify this and they have not. so the logical thing is to err on the stricter interpretation.
Yea, you can transfer the original script information for the purpose of refilling. they were simply reciting the current regulations. so basically, when asked with a direct question, the DEA wiggled around and didn't give a direct answer.
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Yet they say explicitly that original rx info can be transferred (obviously to be filled). Why the eff would they say that then?
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Again that's fine that you interpret it that way but if an independent transferred an original prescription information they could show that as proof and would not get in trouble
How could they get in trouble? If they did then the dea would actually have to admit what they mean lol.
Because they were just reciting current regulations. They avoided the question. They were asked again and again after that commentary and they avoided making any clarification. That's what the lawyers are worried about.
I mean it's not just me...it's the whole industry now. Until the DEA clarifies this, this is the new norm.
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What I'm saying though is no one could get in trouble if an independent transferred it.
They saw the question, the dea said original prescription info is permitted to be transferred.
At this point, if the dea really wanted to crack down, they would have already.
I agree somewhat. I don't think anyone is out to get anybody (at least not the small guys), but I would still not do these transfers right now. I think the most troubling part is that the DEA has refused to clarified further, even knowing that people are confused and even after seeing practicing changes in pharmacies. I think this vagueness gives them more prosecution power later on if they need to use it. I think the corporate lawyers see this as well.
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Oh I won't be transferring anything. I'd rather stay protected under Walgreens.
Oh and if anyone says I'm not, there's no way Walgreens would say your on your own when they specifically state you can't transfer. I definitely won't be arguing that point.
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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. DEA wishes to emphasize that the only changes made to § 1306.25 as part of the NPRM were to revise the text to include separate requirements for transfers of electronic prescriptions. These revisions were needed because an electronic prescription could be transferred without a telephone call between pharmacists. Consequently, the transferring pharmacist must provide, with the electronic transfer, the information that the recipient transcribes when accepting an oral transfer.
I wonder what unchanged means?
Perhaps that the previous industry standard still applied?
Also, I'm throwing away my pocket knife because it's illegal to have one in England.
I don't want to get arrested by American police for doing something that's illegal in the UK.
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Aside from “the original prescription information” what else do you provide as part of a transfer? Do you mail them a commemorative pin? A certificate of authenticity? A cookie?
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I agree on the vagueness part- especially when it involves more than one state.
Say for example a drug like Fioricet that is controlled substance in one state and not the other. Would you still be able to 'transfer/forward' a new/never filled prescription?
What if it was a refill of an RX, but had been issued prn refills in the state it wasn't a control, then transferred the RX to the state to which it is controlled using a real-time database?
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So, I've come up with a solution:
Fill the Rx, verify it, and put it in will call.
THEN RTS IT AND PUT IT ON HOLD.
Boom.
It has now been filled once.
OR, fill the initial fill for 0 tablets.
Nowhere in the regulation does it say "filled and picked up"
Fill the Rx, verify it, and put it in will call.
THEN RTS IT AND PUT IT ON HOLD.
Boom.
It has now been filled once.
OR, fill the initial fill for 0 tablets.
Nowhere in the regulation does it say "filled and picked up"
How does that even work? Drug schedules are determined by the DEA and federal government. In other instances, when two regulations appear contradicting, the federal regulation takes precedence. State regulations can take precedence if they are stricter but not more lenient than federal regulations on the same matter. For state vs state, you have to abide by the state your practicing in. If NY doesn't allow transfers, they're not going to transfer it to you. Don't quote me this is from pharmacy law class like 10 years ago.
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You would have to ask the DEA because neither yours nor anyone's interpretation of that means anything here. Oh wait, looks like people have already asked the DEA and they haven't responded...too bad.
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The DEA did respond. Why do you think they didn't respond? We are talking about their response to the question you are claiming they haven't responded to.
My question is, how many times do they have to answer the same question to satisfy you?
Yea...see that's not how laws work. If it's not written in the laws then it's implied (yadda yadd you can argue that with the courts). If it is written then it is not an implication...it's explicit. The regulation explicitly states ...word for word...that the transfers of controls is only for the purpose of refill dispensing. It doesn't matter if the script is unfilled transferred to you...fillled for 0 tabs...then put back. If you go to fill it again...then that would be the first and original fill and that's not allowed.
No they didn't. They responded with something that was even more vague and confusing and there have been multiple attempts to ask them to clarify again and they haven't. they are seeing that pharmacy practice is changing and they have refused to say anything. this should scare people like you who think they can play mental gymnastics with the current regulations.
Me? LMAO. It's the whole industry. How about they update their regulations? Or respond back to recent inquiries? Make one more statement to clarify that confusing statement they put up previously? No? lol. Like unless you are blind, we are talking about the top 4 chains in the pharmacy business citing the DEA as the sole reason to not do these transfers. All the DEA has to do is come out and say....YES YES YOU CAN. In those direct terms. They could end this whole thing tomorrow morning if they wanted to.
Also, the real important point here is that pharmacy practice is changing because of this confusion. The top 4 chains don't allow these transfers now. The DEA knows about this, and they have not intervened or clarified? I mean if we are misinterpreting their regulations, and have reached out to asked for further clarification, shouldn't they have a duty to respond especially in light of all these corporate actions? The only logical conclusion to draw from this silence is that the DEA wants this stricter interpretation. They don't want you to transfer unfilled controlled scripts.
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And also at a state level. Gabapentin, for example is a controlled substance in Kentucky- i.e. cannot exceed 5 refills, must be included in biennial inventory, etc.
