Controlled Substances: Scheduling, Records, and Dispensing
Scheduling and handling
Controlled substances are placed in Schedules I–V based on abuse potential and accepted medical use. Schedule I has no accepted medical use; Schedules II–V have decreasing abuse potential. Arkansas maintains its own schedule list and may control substances not federally scheduled.
Records and inventory
- Biennial inventory: a complete inventory of controlled substances is required at least every two years, with newly scheduled drugs added and a record kept.
- Records: receipts, dispensations, and inventories must be maintained and retrievable for inspection. Federal rules require records for two years; Arkansas inspection expectations may be broader.
- Order forms: Schedule II drugs require a specific order form (DEA Form 222 or its electronic equivalent). Schedule III–V ordering uses invoices and records.
- Theft/loss: report to DEA and the Arkansas Board; document the circumstances.
- Disposal: follow DEA disposal rules and Arkansas requirements for reverse distributors and take-back programs.
Dispensing rules
Schedule II cannot be refilled; III–V refills are capped (federal: five refills within six months). Partial fills, emergency fills, and multiple prescriptions have specific conditions. Verify prescriber DEA registration and patient identity where required.
Traps
Questions confuse which schedule a drug is in and which record proves it. Another trap is assuming a state schedule matches the federal one exactly.
Worked example
A pharmacy receives a shipment of Schedule II oxycodone but no order form is on file. Do not accept or dispense it until the required order documentation is present and recorded - the order form is the legal record of acquisition.