Prescribing, controlled substances, and recordkeeping
Prescribing, controlled substances, and recordkeeping
Prescribing is the clearest example of a non-delegable dental act. This domain tests the patient-relationship requirement, controlled-substance rules including the prescription drug monitoring program, and the records that must support every prescription.
The prescribing relationship
A dentist may prescribe only in the course of dental practice, for a documented dental condition, after an evaluation sufficient to support the diagnosis. A call from an unfamiliar patient with "tooth pain" is not a basis for an opioid prescription. Chart the complaint, clinical findings, diagnosis, drug, dose, quantity, directions, and the discussion of risks and alternatives.
Controlled substances
DEA registration is required in addition to the Georgia license for Schedule II through V prescribing, and it must match the address where the drugs are stored. Rules to know:
- Schedule II prescriptions may not be refilled and require the documentation the rules impose.
- A prescription must show the dentist's name, license and DEA numbers, patient identification, drug, strength, quantity, directions, and date.
- Controlled substances must be stored securely, inventoried, and reconciled; theft or significant loss must be reported.
- Georgia's PDMP must be checked in the circumstances Georgia law specifies before prescribing covered drugs, and the check should be documented.
Opioids
Georgia's opioid statutes add duties beyond federal law: limits on the quantity prescribed for acute pain, PDMP review, and counseling about risks, storage, and disposal. Document the rationale whenever a controlled substance is chosen over a non-controlled alternative.
Recordkeeping
Prescription records, PDMP queries, and inventory records must be retained and produced on Board request. Failing to keep or produce them is a standalone violation, and it often turns a defensible clinical judgment into an indefensible case.
Worked example
On Saturday a patient texts a photo of a swollen face and asks for "the strong stuff." The dentist forms no diagnosis, checks no PDMP, and phones in hydrocodone. Three problems: no evaluation supporting a diagnosis, no PDMP review, and no record of the decision. The defensible alternative is to arrange an examination or an appropriate emergency referral, determine whether the condition warrants antibiotics or analgesia, and document the reasoning.
Traps
- Treating a phone call or text as establishing a patient relationship.
- Skipping the PDMP because "the pharmacy checks."
- Failing to file prescription and PDMP records with the chart.
- Assuming a Georgia license alone authorizes controlled-substance prescribing.