transfer a newly prescribed controlled medication

[doublehh03]

CVS sent out an email saying we can't do transfers on unfilled controls either.

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[trailerpark]

Is this all happening now over a lawsuit or something? What sparked all this?


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[CetiAlphaFive]

Is this all happening now over a lawsuit or something? What sparked all this?
Sent from my iPhone using SDN mobile app

One member of upper management at Wal-Mart was bored and decided to change Wal-Mart's policy based on a technicality in the dea regulation.

 

[ImyoPushaman]

My state BOP clarified their stance and issued a statement that in my state first fills of controls are not transferable, only refills. For better or worse, at least I have a definitive answer here.

Which state BOP clarified this?

 

[CetiAlphaFive]

DEA clarifies guidance on forwarding unfilled e-prescribed controlled substances

 

[ImyoPushaman]

This actually came up in the Notice of Proposed Rulemaking about electronic prescriptions for controlled substances:
Rules - 2010 - Interim Final Rule With Request for Comment: Electronic Prescriptions for Controlled Substances (Cont'd)

5. Transfers

In the NPRM, DEA confirmed existing regulations regarding the transfer of prescriptions for Schedule III, IV, and V controlled substances. Specifically, under Sec. 1306.25(a) a pharmacy is allowed to transfer an original unfilled electronic prescription to another pharmacy if the first pharmacy is unable to or chooses not to fill the prescription. Further, a pharmacy is also allowed to transfer an electronic prescription for a Schedule III, IV, or V controlled substance with remaining refills to another pharmacy for filling provided the transfer is communicated between two licensed pharmacists. The pharmacy transferring the prescription would have to void the remaining refills in its records and note in its records to which pharmacy the prescription was transferred. The notations may occur electronically. The pharmacy receiving the transferred prescription would have to note from whom the prescription was received and the number of remaining refills.

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 Sec. 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.

This is how I interpret the issue. The recent clarification was meant to address SPECIFICALLY unfilled EPCS, nothing more. I am not subjugated by a corporate interpretation, however. In my current role, I am entrusted to make my own decisions as it pertains to interpretation of the law.

I'd be interested in hearing more individual (NOT THE COMPANY YOU WORK FOR) interpretations. Any independent pharmacist?

If you work for a corporation, keep in mind, just because you get a corporate email dictating how you are to handle a situation DOES NOT mean that's the law... that's YOUR COMPANY'S interpretation of the law. You can follow it, but that doesn't mean you agree with it. I encourage you to make your own mind up, don't blindly accept what you upper management is feeding you.

This is a cluster**** that will only serve to make the lives of more retail pharmacists a living hell as they try to appease the corporate "interpretation" of the law to which they are enslaved... while trying to explain that to the ticked off patient.

Ask yourself why this is the standard corporate interpretation...
"So, Ms Jones, you want me to transfer the Ambien prescription your doctor just phoned in to CVS? Wehehellll, I'm sorry, but that would be ILLEGAL. As we are the original recipient of the prescription, we are the ONLY pharmacy that can fill it. To get it filled elsewhere, you'll have to call your doctor and have a NEW prescription sent to the other pharma... oh what's that? Just go ahead and fill it you say? Sure, we'll be glad to! It should be ready in a few hours!"

Nothing to do with the law, patient care, or anything similar. Just greed.

I wonder what staunch supporters of "Patient Choice" in pharmacy such as the Arkansas BOP have to say about the issue.

 

[ImyoPushaman]

DEA clarifies guidance on forwarding unfilled e-prescribed controlled substances

If you read the letter linked in the story, the NACDS asks for a precise and specific clarification... was that too much to ask? Would it have been too difficult to clarify this in no uncertain terms? But NOOOOOOO.... let's take an already confusing situation and turn it into a REAL cluster**** ... your (federal) tax dollars at work people.

 

[CetiAlphaFive]

This is how I interpret the issue. The recent clarification was meant to address SPECIFICALLY unfilled EPCS, nothing more. I am not subjugated by a corporate interpretation, however. In my current role, I am entrusted to make my own decisions as it pertains to interpretation of the law.

I'd be interested in hearing more individual (NOT THE COMPANY YOU WORK FOR) interpretations. Any independent pharmacist?

If you work for a corporation, keep in mind, just because you get a corporate email dictating how you are to handle a situation DOES NOT mean that's the law... that's YOUR COMPANY'S interpretation of the law. You can follow it, but that doesn't mean you agree with it. I encourage you to make your own mind up, don't blindly accept what you upper management is feeding you.

This is a cluster**** that will only serve to make the lives of more retail pharmacists a living hell as they try to appease the corporate "interpretation" of the law to which they are enslaved... while trying to explain that to the ticked off patient.

Ask yourself why this is the standard corporate interpretation...
"So, Ms Jones, you want me to transfer the Ambien prescription your doctor just phoned in to CVS? Wehehellll, I'm sorry, but that would be ILLEGAL. As we are the original recipient of the prescription, we are the ONLY pharmacy that can fill it. To get it filled elsewhere, you'll have to call your doctor and have a NEW prescription sent to the other pharma... oh what's that? Just go ahead and fill it you say? Sure, we'll be glad to! It should be ready in a few hours!"

Nothing to do with the law, patient care, or anything similar. Just greed.

I wonder what staunch supporters of "Patient Choice" in pharmacy such as the Arkansas BOP have to say about the issue.

I've been doing the same thing I, and every other pharmacist in the nation, have always been doing.

It is common practice to transfer unfilled, on hold controls, and I don't give a **** what some idiot compliance person at Wal-Mart says.

In fact, as soon as DEA flat out says "it's legal, idiots.", I'm submitting a complaint to every board of pharmacy against that compliance person.

 

[Charcoales]

I've been doing the same thing I, and every other pharmacist in the nation, have always been doing.

It is common practice to transfer unfilled, on hold controls, and I don't give a **** what some idiot compliance person at Wal-Mart says.

In fact, as soon as DEA flat out says "it's legal, idiots.", I'm submitting a complaint to every board of pharmacy against that compliance person.

Agreed. This debate is the dumbest time wasting farce ever. No idea why anyone is against it. Very lame and time consuming debacle.

 

[ImyoPushaman]

I've been doing the same thing I, and every other pharmacist in the nation, have always been doing.

It is common practice to transfer unfilled, on hold controls, and I don't give a **** what some idiot compliance person at Wal-Mart says.

In fact, as soon as DEA flat out says "it's legal, idiots.", I'm submitting a complaint to every board of pharmacy against that compliance person.

WORD!

"But if it's against the law, I could lose my license!!!!"

They'd have to take a whole lotta licenses away, Bub...

 

[mnoble]

I've been doing the same thing I, and every other pharmacist in the nation, have always been doing.

It is common practice to transfer unfilled, on hold controls, and I don't give a **** what some idiot compliance person at Wal-Mart says.

In fact, as soon as DEA flat out says "it's legal, idiots.", I'm submitting a complaint to every board of pharmacy against that compliance person.

They recently did say this by the way in a memo, saw it published by APHA's newsletter... even CII's they said can be transferred if electronic.

 

[CetiAlphaFive]

They recently did say this by the way in a memo, saw it published by APHA's newsletter... even CII's they said can be transferred if electronic.

DEA clarifies guidance on forwarding unfilled e-prescribed controlled substances

 

[Apotheker2015]

So I should know this, but you can't transfer a newly prescribed C-III or C-V if you have never filled it before?

Let's say a doctor calls in a C-III and you put it on file, then the patient calls and want it at another pharmacy... you can't transfer it, the doctor has to call it in to the other pharmacy?

Let me guess... you work for Walmart! LOL

 

[txpharmguy]

WAGs position is that because the on hold EPCS can't be forwarded (electronically), we can't transfer them.