01/17/2019

New serial number required on controlled-substances prescription forms

Prescribers advised to comply with new law amid pharmacy rejections

A new state law effective Jan. 1 that requires prescribers to use new controlled-substance prescription pads is causing significant issues, including pharmacy rejections of prescriptions.

After continued discussions with the California Department of Justice, California Pharmacists Association and other stakeholders, CDA now advises members to order the new DOJ-compliant prescription pads from one of the state-approved printers listed on the DOJ’s website. Previously, it was believed that pharmacies would honor prescriptions written on pads compliant before Jan. 1 because of a Dec. 27 Board of Pharmacy notice, but some pharmacy chains continue to reject them.

Importantly, the prescription pads must contain a 15-digit alphanumeric serial number printed in the following format, where “A” represents a letter and “N” a numeral: AAANNNNNNANNNNN

Concerns remain that the serial number on the approved pads does not conform with NCPDP standards. CDA anticipates that the Legislature will undertake action to delay implementation of the law, permitting time to resolve this concern and to ensure patients have uninterrupted access to needed care. However, for the present, Schedule II prescriptions are best provided to patients through e-prescribing or by using a DOJ-compliant pad.

CDA encourages its members to investigate the use of e-prescribing. E-prescribing reduces opportunities for theft and illegal misuse of paper prescription forms and aids in providing timely patient care. CDA published an article on its website and in the September Update that explains how to get started.

CDA will continue to work with the CPhA, the DOJ, the author of AB 1753, Assemblymember Evan Low, and others to reduce implementation issues related to new prescription-form regulations.

CDA will keep members updated through the CDA Update and cda.org.

This article below was originally published: 1/7/19 and updated: 1/11/19.

A new state law requires that tamper-resistant prescription forms for controlled substances have unique serial numbers. These numbers will be linked to corresponding records in California’s prescription-drug monitoring program known as CURES.

The law, Assembly Bill 1753, which took effect Jan. 1, 2019, has experienced significant implementation challenges. CDA and the bill’s author, Assemblymember Evan Low, had anticipated that the Department of Justice would establish an implementation period for the law, supporting transition to the new forms and uninterrupted patient care. However, CDA learned on Jan. 4 that the DOJ was attempting to implement the law’s requirement immediately.

CDA communicated this information to members in an article published Jan. 7 on cda.org and in the Jan. 9 newsletter. The medical board and board of pharmacy, concerned about interruptions in patient care, issued advisory notices on Dec. 28 that valid prescriptions should continue to be filled, even when written on noncompliant forms. The dental board issued a similar advisory notice Jan. 4.

Implementation was further complicated when it was learned that the suppliers listed on the DOJ’s website as offering compliant forms were found to have incorrectly formatted serial numbers and were therefore not compliant. CDA responded to this news with an email alert to members on Jan. 11.

During this current transition period, while CDA awaits confirmation that fully compliant forms are available for order on the DOJ website, dentists may want to attach the Board of Pharmacy’s advisory to all Schedule II prescriptions that are written on a noncompliant prescription form to facilitate proper dispensing. CDA is also working with the California Pharmacists Association to ensure pharmacists who do not fill valid Schedule II prescriptions are made aware of the board’s advisory notice.

Dentists who have a valid prescription rejected and are not able to resolve it directly with the pharmacist are advised to email the information, along with the pharmacy location, to Teresa Pichay.

CDA will continue to provide information about implementation, enforcement and compliance to members as soon as it becomes available. Prescribers can continue to use the noncompliant forms when prescribing noncontrolled substances such as antibiotics, but forms that will not be used must be destroyed. 

Prescribers should consider moving to e-prescribing for controlled substances. CDA published an article on its website and in the September Update that explains how to get started.



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Many bills were introduced over the past year to combat the opioid epidemic in California, as CDA previously reported. Here is an overview of CDA-supported legislation in the areas of e-prescribing, informed consent, interstate data sharing and prescription-pad requirements, that Gov. Jerry Brown signed into law in September and how these bills will affect the practice of dentistry.

A dentist who stores controlled substances must follow both state and federal rules for storage, inventory and disposal of those drugs. DEA registration is required for each address where a dentist stores controlled substances.

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