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Prescribers can use existing controlled-substance Rx forms until January 2021

March 05, 2019 3364

A bill to address problems implementing new requirements for controlled-substance prescription forms sailed through the California Legislature and is expected to receive Gov. Gavin Newsom’s signature this week.

Assembly Bill 149 delays the requirement that prescribers use a new form approved by the Department of Justice as part of an earlier bill that passed last year. Because the new legislation is being pushed through as an urgency statute, it will take effect immediately, but it gives prescribers time to comply.

Starting Jan. 1, 2021, when prescribing controlled substances, prescribers will be required to use forms with unique serialized numbers compliant with National Council for Prescription Drug Program standards and that are linked to corresponding records in California’s prescription-drug monitoring program known as CURES. These forms have not yet been developed and will be different from the forms the DOJ incorrectly approved in January 2019, as it was learned the serial number on those forms did not conform to national standards.

Until Jan. 1, 2021, pharmacists are authorized to fill, compound or dispense any prescriptions for controlled substances written on a form that was valid prior to Jan. 1, 2019, that doesn’t include the unique serial number, or a form approved by the DOJ in January 2019 with an incorrectly formatted serial number. Neither of these forms, however, will be accepted beginning Jan. 1, 2021.

CDA actively supported AB 149 by Assemblymember Jim Cooper (D-Elk Grove) to resolve issues that began in early January when the previous bill, AB 1753, took effect and immediately required the availability and use of the new controlled-substance prescription forms. The absence of an expected transition period left prescribers and pharmacists scrambling to interpret and follow the law, and CDA Practice Support received numerous calls from dentists who reported having their prescriptions for controlled substances denied by pharmacists. CDA, other provider groups and the DOJ worked together to achieve a short-term resolution but issues with prescription fulfillment persisted.

Prescribers may want to consider switching to e-prescribing for controlled substances. E-prescribing for all medicines will be mandated except in limited circumstances by Jan. 1, 2022. CDA published an article on its website and in the September Update that explains how to get started.

CDA will remind dentists about the new law’s requirements as the compliance deadline nears and will report any new developments in the Update and on

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