Controlled Substances: Scheduling, Registration, Prescribing, Dispensing, Records, and Reporting
Scheduling and registration
Illinois adopts the five federal schedules. Schedule I has no accepted medical use; CII carries the tightest controls; CIII–V loosen progressively. Every dispenser needs a federal DEA registration plus an Illinois controlled substance license. Federal registration renews every three years; report address or ownership changes.
Prescribing and dispensing
CII: no refills; written, electronic (EPCS), or emergency oral followed by a written/electronic original within seven days. Partial fills: LTCF or terminally ill patients up to 60 days; other CII partial fills within 30 days. CIII–V: up to five refills within six months of issue. Verify the prescriber's DEA number and state authority - Illinois APRNs and PA-Cs may prescribe CII within statutory limits, so check the collaborative agreement, not just the number.
Records and reporting
Biennial inventory (plus initial and on change of registrant), kept two years; Form 222 or CSOS for CII ordering; Form 106 for theft or significant loss with notice to Illinois authorities; Illinois PMP reporting of dispensed controlled substances, generally within 24 hours.
Traps
Treating the 60-day partial fill rule as universal. Believing a CII can be refilled verbally. Forgetting the PMP report is the dispenser's duty, not the prescriber's. Reading a DEA number as proof of state prescribing authority.
Rule of thumb
For any controlled substance, ask three questions in order: Is the prescriber authorized in Illinois? Is the prescription valid under CII or CIII–V rules? Has the dispensation been reported?