Interstate Transfer Requests: One CII, One CIV, and One Emergency Supply

Generally yes, but only once, and only under the conditions for Schedule II transfers. Since the 2023 DEA rule, a Schedule II prescription may be transferred one time between DEA-registered retail pharmacies for the purpose of initial filling, at the request of the patient or the prescriber. This prescription has not been filled, so it is eligible; if it had already been dispensed, there would be nothing left to transfer because no refills are authorized.

Process requirements:

• The transfer must occur pharmacist-to-pharmacist (or by other direct communication between the two pharmacies), not patient-mediated.
• The transferring pharmacy must record on the prescription record the receiving pharmacy's name, address and DEA number, the receiving pharmacist's name, and the date of transfer, and must void or cancel the original so it cannot be filled twice.
• The receiving pharmacy must record the transferring pharmacy's name, address and DEA number, the transferring pharmacist's name, the original prescription information (patient, drug, quantity, directions, prescriber, date issued), and the date of transfer.
• Both pharmacies retain the records for at least two years and must be able to produce them on inspection.

Before proceeding: confirm the prescription would be valid if it had been issued in Utah (a 12-day-old Schedule II is not a timeliness problem), confirm the transfer is between two retail pharmacies (the rule does not extend to every practice setting), and confirm current Utah law has not added a restriction. Also confirm the Idaho pharmacy has actually voided its copy - the most common failure mode is a duplicated live prescription.

Different rule set. Schedule III–V prescriptions may be transferred between pharmacies for refill purposes, one time only (21 CFR 1306.25). Unlike the Schedule II rule, the transfer may occur after the original has been dispensed, and the receiving pharmacy may then refill up to the remaining authorized refills.

Required entries:

• Transferring pharmacy: receiving pharmacy's name, address and DEA number; receiving pharmacist's name; date of transfer; notation that the prescription was transferred.
• Receiving pharmacy: transferring pharmacy's name, address and DEA number; transferring pharmacist's name; original prescription number and date issued; date of first fill; number of refills remaining; date of last refill.

Limits to verify: a Schedule IV prescription cannot be refilled more than five times and cannot be refilled more than six months after the date of issue. Confirm this prescription is inside that window (20 days old with 3 refills remaining appears fine) and confirm Utah has no shorter refill window. Also confirm the alprazolam is not being paired with an opioid in a way that changes the risk picture - if this patient also receives opioids, the same red-flag and PDMP analysis from any other controlled substance fill applies, and a courtesy transfer does not excuse it. Finally, avoid transferring the same prescription twice: mark the record so a later request is refused.

Utah permits a limited emergency supply of a non-controlled maintenance medication when the prescriber cannot be reached. Levothyroxine fits the fact pattern: chronic maintenance therapy, no controlled substance issue, and an imminent gap in therapy.

Framework: the pharmacist may dispense a limited quantity (Utah's provision has historically been framed as a one-time emergency supply on the order of a 30-day quantity - confirm the current statutory/rule quantity and any per-drug or per-period limits before dispensing) for a drug that is not a controlled substance, where the pharmacist has made reasonable efforts to contact the prescriber and the interruption would be harmful. The emergency fill is documented and the prescriber is notified as soon as practicable so a new prescription can be issued.

Documentation: date and time; drug, strength, quantity dispensed and days supplied; the patient's statement of need; every contact attempt (phone, fax, portal) with times and outcomes; the clinical rationale; the fact that the prescriber was notified afterward; and the pharmacist's identity. Note that this is not a refill of the original prescription - it is a separate emergency authorization and must not be billed as authorized refills or extended repeatedly. A second emergency request for the same drug within the same period should trigger a call to the prescriber's covering physician, not another exception.