Controlled Substances: Federal CSA and the New Mexico CSA
Federal backbone
Registration is per location and per schedule. Schedule II prescriptions cannot be refilled and cannot be filled more than 90 days after the issue date. Emergency oral CII orders require a written or electronic follow-up within 7 days. Schedule III–V prescriptions allow up to 5 refills within 6 months of issue. Partial fills of CII: the remainder must be supplied within 72 hours or the balance is forfeited, except for patients in long-term care or with terminal illness, where partial fills may extend up to 60 days from issue.
Records and accountability
Biennial inventory, DEA Form 222 or CSOS for CII ordering, DEA Form 106 for theft or loss (report promptly on discovery), and Form 41 for destruction. Pharmacists bear corresponding responsibility: a prescription that is not issued for a legitimate medical purpose in the usual course of professional practice cannot be filled, and red flags must be resolved and documented.
New Mexico overlay
The New Mexico Controlled Substances Act (NMSA ch. 30, art. 31) is administered by the Board of Pharmacy. Dispensers report controlled substance dispensing to the state prescription monitoring program, and prescribers have PMP query obligations. Where state law is stricter than federal law, follow the stricter rule.
Trap and worked example
Candidates wrongly assume a CII can be transferred like a CIII, that a mid-level prescriber's DEA number authorizes CIIs without state authority, or that 'refill' language on a CII is merely an error to be corrected. A CII presented 100 days after the written date must be refused; the prescriber must issue a new prescription.