One-Time Transfer of a Schedule IV Prescription
A 58-year-old woman moves from Cedar Rapids to Sioux City and presents at a new pharmacy with a prescription for lorazepam 1 mg, quantity 30, 'one tablet at bedtime,' with two refills remaining. The prescription was originally filled at a Cedar Rapids pharmacy on January 15; one refill was dispensed on February 10. The new pharmacy calls the original pharmacy and obtains the prescription information. The patient wants the next refill today, March 1. The original pharmacy is open and willing to transfer. The new pharmacist sees the prescription is for a Schedule IV controlled substance and the patient has no other controlled substances on the Iowa PMP. The patient asks if she can transfer the remaining refills to a pharmacy near her winter home in Arizona next month.
1. May the new pharmacy accept the transfer and dispense the next refill? What federal and Iowa requirements apply?
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Yes, if the transfer is done correctly. Federal law permits a one-time transfer of prescription information for a Schedule III-V controlled substance between pharmacies for the purpose of initial filling or refill, provided the transfer is permitted by state law and both pharmacies are DEA-registered. Iowa does not prohibit this one-time transfer, so the new pharmacy may accept it and dispense the next refill. The transferring pharmacist must record on the original prescription that it was transferred, the date, the receiving pharmacy, and the receiving pharmacist. The receiving pharmacist must obtain and record the original prescription number, date, original pharmacy, and remaining refills. The transfer must be communicated directly between pharmacists or by a secure system, not by the patient.
2. How many times may this prescription be transferred, and what should the pharmacist tell the patient about Arizona?
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The prescription may be transferred only once. After the Cedar Rapids pharmacy transfers it to Sioux City, the remaining refills cannot be transferred again to Arizona. The pharmacist should explain that the patient will need a new prescription from her prescriber for the Arizona pharmacy, and that the Arizona pharmacy must verify the prescriber's DEA registration and authority to prescribe in Arizona. The patient should not assume the Sioux City pharmacy can simply send the file to Arizona. If the prescriber issues a new prescription, the Arizona pharmacy can fill it under its own state law. The pharmacist should document the explanation and the one-time nature of the transfer.
3. What records must each pharmacy keep for this transfer?
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The transferring pharmacy must keep a record showing the original prescription number, the date of transfer, the name and address of the receiving pharmacy, the name of the receiving pharmacist, and the fact that the original prescription is no longer active for refills at that pharmacy. The receiving pharmacy must keep the original prescription number, the original date of issue, the name and address of the transferring pharmacy, the name of the transferring pharmacist, the remaining refills, and the date the transfer was received. Both records should be readily retrievable for inspection. The receiving pharmacy should also document the refill it dispenses on March 1. If the transfer is challenged, these records show that the one-time rule and the direct pharmacist-to-pharmacist communication requirement were met.