A CII Prescription With a Missing Element
A prescriber's office sends an electronic prescription for oxycodone 10 mg, 60 tablets, one every 6 hours as needed, to a community pharmacy. The electronic record shows the prescriber's name and DEA number, the patient's name and address, the drug, strength, quantity, directions, and the date. The pharmacist notices the prescription does not include the patient's date of birth, and the prescriber's DEA number is entered with a transposed digit that does not match the DEA registration on file. The prescriber's office is closed for the weekend. The patient is in the lobby and says he is leaving on a flight tomorrow. The pharmacy has no prior relationship with this prescriber.
1. Which elements are missing or incorrect, and what is the pharmacist's obligation before dispensing?
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A valid Schedule II prescription must include the patient's name and address, the drug name, strength, dosage form, quantity, directions, prescriber's name, address, and DEA number, and the date of issue. The patient's date of birth is not a federally required element, so its absence alone does not invalidate the prescription; the pharmacist can obtain it from the patient for the record. The transposed DEA number is a real problem: the pharmacist must verify the prescriber's DEA registration and the authority to prescribe the drug. A DEA number that does not match the registration on file cannot simply be corrected by the pharmacist. The pharmacist should verify the prescriber's registration through the appropriate verification system and, if the number is genuinely wrong, contact the prescriber to obtain a corrected prescription. The pharmacist may not alter the prescriber's DEA number on a Schedule II prescription.
2. The patient is flying out tomorrow. Can the pharmacist dispense on the basis of the oral assurance of the prescriber's staff, or use the emergency oral prescription exception?
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The emergency oral exception applies when a pharmacist receives an oral prescription for a Schedule II drug in a genuine emergency and cannot obtain a written prescription. In that case the pharmacist may dispense, but the prescriber must provide a written prescription within seven days, and the pharmacist must document the emergency. Here the situation is not a medical emergency; it is a travel deadline. The pharmacist should not use the emergency exception to bypass the verification problem. The pharmacist should attempt to reach the prescriber through the office's after-hours line or an alternate contact, verify the DEA number, and obtain a corrected electronic prescription. If the prescriber cannot be reached, the pharmacist should explain that the prescription cannot be filled until the discrepancy is resolved. The patient's travel plans do not override the verification requirement.
3. If the pharmacist later learns the prescriber's DEA number was correct and the transposition was a data-entry error by the office, can the pharmacist correct the record and dispense?
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The pharmacist may not unilaterally correct a prescriber's DEA number on a Schedule II prescription. The proper course is to have the prescriber's office issue a corrected prescription or provide a documented correction that the pharmacist can verify. Once the pharmacist has verified the prescriber's registration and authority, and has a corrected prescription or documented correction, the pharmacist may dispense. The pharmacist should document the verification steps, the correction, and the date. If the pharmacy's system allows annotation of clerical errors, the pharmacist should follow Arkansas and federal guidance on what may be corrected and by whom, and should not treat a DEA number as a clerical item the pharmacist can fix alone.