Federal Controlled Substances Act
Registration and ordering
A pharmacy registers with DEA at each location and renews every three years. Schedule II stock is ordered on DEA Form 222 (or CSOS) under a power of attorney; Schedules III–V are ordered on invoices that become your receiving record. A power of attorney may name agents but the registrant remains responsible.
Records, inventory, security
Take an initial inventory and a biennial inventory thereafter. Count Schedule II exactly; Schedules III–V may be estimated unless the container holds more than 1,000 units. Keep records two years, in a manner that is readily retrievable; Schedule II records are typically kept separately. Security must provide substantial deterrence - locked storage, limited keys, employee screening. Report theft or significant loss on DEA Form 106 once discovered; destroy via DEA Form 41 or a reverse distributor.
Dispensing limits
The core numbers: Schedule II cannot be refilled; a Schedule III–V prescription may be refilled up to five times but not beyond six months from the date issued, whichever comes first. Partial filling of a CII is allowed if the pharmacist cannot supply the full quantity, with the balance within 72 hours, or within 60 days for a long-term care resident or terminally ill patient. An oral CII order in a true emergency requires a written follow-up within seven days. A CII prescription may be transferred once, only if it is an electronic prescription, between DEA-registered pharmacies.
Traps
The five-refill and six-month limits are both caps - whichever arrives first governs. An oral emergency CII is not a refill. A DEA Form 106 reports loss; a Form 41 documents destruction. Corresponding responsibility means resolving red flags before dispensing, not merely holding a technically complete prescription.
Rule of thumb: if a drug is CII, assume written or electronic only, no refills, and annual-form ordering.