Patient-Requested Partial Fill of a Stimulant
On March 3, a 19-year-old college student in Iowa City presents an electronic prescription dated February 21 for amphetamine/dextroamphetamine 20 mg, quantity 60, 'one capsule daily,' no refills, from a psychiatrist 30 miles away. The pharmacist has the full quantity in stock. The patient asks to fill only 14 capsules because she is worried about insomnia and wants to see how she responds before committing to a full month. She plans to return in two weeks for the rest. The pharmacist notes this is a new medication for her and the prescription is already 10 days old. The patient has no history of early refills and the Iowa PMP shows only this stimulant and no other controlled substances.
1. Can the pharmacist partially fill this Schedule II prescription at the patient's request? If so, what is the controlling time limit?
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Yes. Under 21 CFR 1306.13(a), a pharmacist may partially fill a Schedule II prescription at the request of the patient or prescriber. The pharmacist may dispense 14 capsules and retain the balance, but the remaining quantity must be dispensed no later than 30 days after the date the prescription was written. Here the prescription was written February 21, so the remainder must be dispensed by March 23, not 30 days after March 3. The pharmacist should explain this to the patient before she leaves, because she plans to return in two weeks but the legal window is measured from the original date written. If she waits past March 23, the remainder is void and a new prescription is needed.
2. What must the pharmacist record on the prescription and in the pharmacy system?
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The pharmacist must make a clear record of the partial fill on the prescription record. That record should show the date of the partial dispensing, the quantity dispensed (14), the quantity remaining (46), and the identity of the dispensing pharmacist. The original prescription and the electronic record should both reflect that the remainder is outstanding until it is dispensed or expires. The pharmacist should also document that the partial fill was at the patient's request, not because of a supply shortage. If the remainder is later dispensed, the pharmacist records that date and quantity as well. Good records let an inspector or another pharmacist determine whether the 30-day window was met.
3. The patient returns on April 1 and asks for the remaining 46 capsules. What should the pharmacist do?
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The pharmacist must not dispense the remainder. The prescription was written February 21, and the 30-day period for dispensing the balance ended on March 23. After that date, the unfilled portion is void; the pharmacist cannot extend the period by agreement or by treating April 1 as a new fill date. The pharmacist should explain the rule, decline to dispense the balance, and tell the patient to contact the prescriber for a new prescription if continued therapy is appropriate. The pharmacist should document the refusal and the reason. Dispensing after the 30-day window would violate the federal partial-fill rule and could support Board or DEA action.