Receiving Controlled Substance Prescriptions
A comprehensive overview of how to properly receive, evaluate, and validate controlled substance prescriptions to prevent fraud, diversion, and regulatory violations.
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Receiving controlled substance prescriptions is a critical control point in preventing prescription fraud, misuse, and diversion. Pharmacy staff must ensure that every prescription meets federal and state requirements before processing or dispensing.
What is a Prescription?
A prescription is an order for a medication intended to be dispensed to an ultimate user (the patient or their authorized representative).
Valid Prescription Requirement
All controlled substance prescriptions must be issued for a legitimate medical purpose by an authorized prescriber acting within their professional scope. Pharmacists share responsibility for ensuring prescriptions are valid prior to dispensing.
Authorized Prescribers
Only properly registered and authorized practitioners may issue controlled substance prescriptions. These may include:
- Physicians
- Dentists
- Podiatrists
- Veterinarians
- Mid-level practitioners (e.g., physician assistants, nurse practitioners), as permitted by state law
Prescriber credentials and registration numbers (including DEA numbers) must be verified at the point of service.
State regulations may impose additional requirements and restrictions.
General Requirements for Controlled Substance Prescriptions
A valid controlled substance prescription must include:
- Date issued and prescriber signature
- Patient’s full name, date of birth, and address
- Prescriber’s full name, address, and DEA number
- Drug name, strength, dosage form (if applicable)
- Quantity prescribed
- Directions for use
- Number of refills authorized (if applicable)
- Any other state specific regulations
Additional requirements:
- Paper prescriptions must be written in ink, indelible pencil, or printed
- Prescriptions must be manually signed on the date issued
- Prescriber agents may prepare prescriptions, but the prescriber must sign
Types of Controlled Substance Prescriptions
Written Prescriptions
- Must include all required elements
- Must be manually signed by the prescriber
- May require tamper-resistant paper depending on state or payer rules
Verbal Prescriptions
- Must be promptly reduced to writing by the pharmacist
- Must include all required elements except a physical signature
Electronic Prescriptions
- Must be created, transmitted, and stored using compliant systems
- All associated documentation must be stored electronically and linked to the prescription
- Systems must allow secure storage and easy retrieval
Duplicate Prescriptions
- If both electronic and paper/verbal prescriptions are received for the same medication:
- Confirm whether a duplicate exists
- Void one prescription appropriately after verification
Schedule II Controlled Substance Prescriptions
Key Requirements
- Must be issued as written or electronic prescriptions (verbal only allowed in emergencies)
- No refills permitted
- Must meet all federal and state requirements
Expiration and Validity
- No federal expiration date, but state laws may apply stricter regulations
- Best practice includes verifying older prescriptions with the prescriber
Quantity and Supply
- No federal limits on quantity or days’ supply
- Must be medically necessary and comply with state laws
Multiple Prescriptions (Up to 90-Day Supply)
Permitted if:
- Allowed pursuant to state regulations
- Each prescription is issued separately
- Each includes an earliest fill date (if applicable)
- If none of the prescriptions contain an earliest fill date, contact the prescriber to have them reissue with the earliest fill dates and void the ones received
- All prescriptions are for legitimate medical purposes
- Prescriber determines no undue risk of diversion
Faxed Prescriptions
Permitted in limited cases (if allowed by state law):
- Long-term care facility (LTCF) patients (must be clearly documented on the prescription)
- Hospice patients (must be clearly indicated)
Allowable Changes
The DEA is evaluating regulations regarding changes pharmacists can make to schedule 2 controlled substance prescription orders. Currently, the DEA recommends pharmacists consult their state board of pharmacy for interim rules.
Schedule III–V Controlled Substance Prescriptions
Accepted Formats
- Written prescriptions
- Faxed prescriptions
- Electronic prescriptions
- Verbal prescriptions
- Transfers (for refills, where permitted)
- States may impose additional requirements
Refill Rules
- Up to 5 refills within 6 months from the date of issue
- After that, a new prescription is required
- State laws may impose stricter limits
Documentation Requirements
- Pharmacy systems must track original prescription details and refill history
- Pharmacists must verify accuracy of refill records
Allowable Changes
Each pharmacist should consult their state board of pharmacy to determine allowable changes made to schedule 3-5 controlled substance prescriptions.
Key Takeaway
Thorough evaluation of controlled substance prescriptions at the point of receipt is essential to ensuring compliance and preventing diversion. By verifying prescriber authority, confirming required elements, and identifying potential issues early, pharmacy staff help protect patients, the pharmacy, and the community.
Disclaimer: These tools and templates are intended for general informational purposes and are provided by Montana Family Pharmacies as a service to pharmacies. While we try to keep the information timely and accurate, we make no guarantees. These tools and templates are not a substitute for legal, regulatory, or professional advice.
Policies and procedure, templates, checklists, and other tools should be customized to fit the specific needs and regulatory requirements of your pharmacy.
Montana Family Pharmacies disclaims any liability for any damages, losses, or other consequences arising from the use or reliance on the tools or policy templates.