CS E Flashcards
C.S. Prescriptions: In what form can they be prescribed?
Official NYS prescription form (ONYSRx)
Electronic prescription
Oral RX
Out of state prescription
What does practitioner need to keep record of when prescribing CS?
Practitioners must maintain Written record (chart)
Administration
Dispensing
Prescribing
of all controlled substances
What data must practitioners keep when they prescribe a controlled substance?
Patient identification data
Chief Complaint
Present illness
Physical Exam
Diagnosis, with other data to support
Drug
Name
Strength
Directions for use
Can a prescription for CS be pre-printed or pre-written?
No. May not issue CS prescriptions prior to examining the patient.
The use of preprinted prescriptions which indicate the controlled substance, strength, dosage and/or quantity is prohibited
Unless they are printed at the time the practitioner is seeing the patient
Prescriptions may not be written ahead of time
Must be written and dated the date the practitioner saw and examined the patient.
After an initial examination is made, during future examinations the prescriber must take into accountt:
Drug prescribed
Patient’s condition
Patient’s history
Disposition of CS given
CS Prescriptions Use: Temporary absence of initial prescriber
What happens?
Conditions
Another PR can prescribe for the initial PR (continuing therapy) if:
PR has direct access to patient’s medical record and record indicates continuing CS
Direct and adequate consultation with primary PR
Cannot access other records?
Secondary PR must document activity and transmit to primary PR for inclusion in patient record
Can a PR prescribe CS based on records from another PR or hospital?
Yes. Primary PR may prescribe from record that contains result of an exam from another consulting physician or hospital
Prescribing CS before examination of patient: Conditions
PR may prescribe BEFORE examining patient
Previous relationship
Emergency
Immediate administration of the drug is necessary, and no alternative is available
Who May Issue CS
Issued by PR authorized to prescribe CS pursuant to his/her professional license
Registered with DEA or exempted
Who May Issue Electronic Rxs &
Exceptions
PRs:
Using an electronic application consistent with federal regulations
Registered with NYSDOH
Exceptions:
PR may issue an Official New York State prescription (ONYSRx) form, oral prescription or a fax of a manually signed ONYSRx.
Veterinarians
Temporary technological failure
Temporary electrical failure
Economic hardship
Technological limitations not reasonably within the control of the practitioner
Exceptional circumstances by PR
An approved waiver not >
Must notify DOH upon resolution
The PR reasonably determines that it would be impractical for the patient to obtain substances prescribed by an electronic prescription in a timely manner, and such delay would adversely impact the patient’s medical condition.
Quantity of the controlled substance not to exceed a 5-day supply
To be dispensed by a pharmacy located outside the state.
Commissioner of Health Blanket Waivers [ What circumstances allow a PR to issue a written ONYSRx or oral Rx for controlled & non-controlled]
Does the PR have to indicate the circumstance on the Rx?
Prescriptions with complicated directions
Prescriptions with directions longer than 140 characters
Compounded prescriptions containing 2 or more products
Compounded infusion prescriptions containing 2 or more products
A prescription containing certain elements required by the FDA such as an attachment
Approved protocols under expedited partner therapy
Approved protocols under collaborative drug management
Response to a public health emergency that would allow a non-patient specific prescription
Approved research protocol
A non-patient specific prescription for an opioid antagonist
To be communicated to a pharmacist serving as a vendor of pharmaceutical services, by an agent who is a health care practitioner, for patients in nursing homes and residential health care facilities
A pharmacist serving as a vendor of pharmaceutical services dispensing in conformity with the above.
The PR is not required to indicate the circumstance on the written ONYSRx or oral prescription.
DEA Manual:
Should you fill a Rx if you think it is not for professional treatment?
What would be the consequences?
No. An order purporting to be a prescription issued not in the usual course of professional treatment or in legitimate and authorized research is an invalid prescription within the meaning and intent of the CSA
The person knowingly filling such a purported prescription, as well as the person issuing it, shall be subject to the penalties provided for violations of the provisions of law relating to controlled substances
DEA Red Flags
Patients request brand names by slang terms
People who are not regular patrons or residents of the community
Showing up with Rxs from the same prescriber
“Pattern prescribing”
Prescriptions for the same drugs and the same quantities coming from the same doctor
Prescribing combinations or ‘cocktails’ of frequently abused controlled substances
The prescribing of controlled substances in general
Quantity and strength questions
Paying cash
Customers with the same diagnosis code from the same doct
Action taken against the prescriber by state or federal regulatory agencies
Especially for controlled substances
PMP: patient getting Rxs from several prescribers
“practitioner shopping”
These flags are not stop signs
Practitioner ordering CS:
What classes are allowed
No practitioner authorized to prescribe CS may obtain Schedule II’s except through the use of DEA 222’s.
IF that practitioner wants to dispense controlled substances
III,IV,V through a distributor or manufacturer
C.S. Prescriptions: What Rx is not allowed
Not Rx for detoxification or maintenance treatments (e.g. methadone).
must be in a methadone program
Exception is buprenorphine
C.S. Prescriptions: Who can fill
Persons entitled to fill :
Pharmacists
Not registered individually
employed in registered pharmacy
employed in registered institution.
C.S. Prescriptions Manner of Issuance
Written Rxs
Must have what on it
All written RXs for C.S. must provide:
Patient info:
Name (FS)
Address (FS)
Age (S)
if an animal, the species and the name and address of owner (custodian)
Sex (S) = NYS Sch II & Benzos on
Prescriber info:
Name (Imprinted) of prescriber (S)
Address (FS)
Signature (FS)
Telephone number (S)
Date signed by PR (FS)
Date prepared and signed and patient seen
DEA registration number (FS)
Specific directions for use (including but not limited to):
Dosage (e.g. 250mg)
Standard name (e.g. Xanax )
Frequency of dosage (e.g. tid)
MDD
Not “use as directed”
Label as to content
name of drug,strength, etc
Prescription must include all other laws pertaining to form of RX:
Substitution
Imprinted name of prescriber
DAW box etc.
Must be in ink, typewritten or indelible pencil
NOT erasable pens!
One Rx per blank (§6810)
Label as to content
