Transferring a Schedule IV While a Schedule II Stays Behind
A patient is relocating from Billings to Missoula, Montana, and visits Pharmacy B with two prescriptions that were dropped off at Pharmacy A in Billings but never filled. The first is alprazolam 0.5 mg tablets, quantity 60, with two refills, issued by a Montana physician. The second is amphetamine/dextroamphetamine extended-release 20 mg capsules, quantity 30, with no refills, issued by the same physician. Both prescriptions are otherwise valid and within their fill windows. The patient asks Pharmacy B to "transfer both" so she can pick them up in Missoula. Pharmacy A is a retail pharmacy and is open. Pharmacy B is also a retail pharmacy. The patient has not yet paid for either prescription. The pharmacist at B has verified the patient's identity and has the prescriber's contact information. Pharmacy B has both drugs in stock.
1. Can Pharmacy B transfer the alprazolam prescription? Explain the federal conditions and any Montana limitation.
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Yes, but only because the alprazolam prescription has not been filled and is being transferred for initial filling. Alprazolam is a Schedule IV controlled substance. Under 21 CFR 1306.25, a prescription for a Schedule III, IV, or V controlled substance may be transferred between retail pharmacies for initial filling, at the patient's request, one time only. The transfer must be communicated pharmacist-to-pharmacist; the transferring pharmacist must cancel the original and record the receiving pharmacy's name, address, and DEA number, the receiving pharmacist's name, and the date; the receiving pharmacist must record the transferring pharmacy's information and the fact of the transfer. Montana follows the federal rule for CIII-V transfers. Because the prescription has not been filled, Pharmacy B can treat the transferred prescription as the original for the initial fill and retain the two refills.
2. Can Pharmacy B transfer the amphetamine/dextroamphetamine prescription? Why or why not?
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No. Amphetamine/dextroamphetamine extended-release is a Schedule II controlled substance. Federal law does not permit the transfer of a Schedule II prescription between pharmacies, even for initial filling. The patient must obtain a new prescription from the prescriber, either electronically or on paper as Montana permits. Pharmacy B should not accept a telephone transfer, a faxed copy offered as a transfer, or a "courtesy fill" based on Pharmacy A's verbal confirmation. A new prescription is required, and the prescriber must issue it in a form that satisfies the CII rules. If the prescriber sends a new electronic prescription, Pharmacy B must verify that it meets the electronic prescription requirements, including identity proofing and two-factor authentication.
3. What documentation must the transferring and receiving pharmacists complete for the alprazolam?
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For the alprazolam, the transferring pharmacist at Pharmacy A must record on the original prescription: the date of transfer, the name and address of Pharmacy B, Pharmacy B's DEA number, the name of the receiving pharmacist, and the transferring pharmacist's name. Pharmacy A must cancel the original and note that it has been transferred. Pharmacy B must record: the date, the transferring pharmacy's name, address, and DEA number, the transferring pharmacist's name, and the receiving pharmacist's name. Both records must be retrievable for at least two years. Because the transfer is one-time only, Pharmacy B must not later transfer the same prescription to a third pharmacy. If the patient later wants to move the remaining refills, a new prescription is required.