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Interactive Guide to DEA Prescription Rules



DEA Controlled Substance Prescription Guide

An interactive tool to clarify DEA regulations for prescribing controlled substances.

Key Principle: Corresponding Responsibility

A foundational concept in controlled substance dispensing is the shared responsibility between the prescriber and the pharmacist. The law does not place the entire burden on the prescriber. Pharmacists have a "corresponding responsibility" to ensure that every controlled substance prescription they dispense is issued for a legitimate medical purpose by a practitioner acting in the usual course of their professional practice. This guide helps clarify the technical requirements, which is the first step in upholding this critical professional duty.

This section covers traditional prescriptions written on paper script pads. The central requirement for this format, regardless of drug schedule, is the practitioner's original, manual signature.

Schedule II

Requirements

  • Must be a written prescription.
  • Must be manually signed by the practitioner.

📝MPJE Tip

Always ensure any paper prescription has a manual, "wet" signature. A signature stamp is never acceptable for any controlled substance.

Schedules III, IV, & V

Requirements

  • Must be manually signed by the practitioner.

✔Best Practice

The rule is identical to Schedule II for paper scripts: a manual signature is mandatory. Do not accept stamped signatures.

This applies to prescriptions generated on a computer and then printed. It's critical to understand that these are legally considered paper prescriptions, not electronic ones, and must be handled as such.

Schedule II

Requirements

  • Must be manually signed by the practitioner after printing.
  • The original signed prescription is required before dispensing.

📝MPJE Tip

A computer-generated, printed prescription is legally a paper prescription. It is NOT an electronic prescription and needs a wet signature.

Schedules III, IV, & V

Requirements

  • Must be manually signed by the practitioner after printing.

✔Best Practice

Same as Schedule II, these must be manually signed. The legal classification as a "paper prescription" is the key takeaway.

The rules for faxed prescriptions represent a major point of difference between drug schedules. Understanding when a fax can serve as the original prescription is essential for compliance.

Schedule II

Requirements

  • Fax is for advance notice only.
  • The original, manually signed paper prescription must be presented before dispensing.

⚠Exceptions

A fax can serve as the original for:
1. LTCF patients.
2. Hospice patients.
3. Compounded narcotics for direct patient administration (e.g., infusion).

Schedules III, IV, & V

Requirements

  • A fax of a manually signed paper prescription is acceptable as the original.
  • Can be transmitted by the practitioner or their agent.

📝MPJE Tip

DON'T dispense a routine faxed CII without the original hardcopy. DO differentiate the fax rules: for CIII-V, the fax can serve as the original.

Oral, or phoned-in, prescriptions are another area with critical differences between schedules. Routine oral prescribing is prohibited for Schedule II drugs but common for others.

Schedule II

Requirements

  • Only permissible in declared emergency situations.
  • Routine oral prescriptions are strictly prohibited.

Schedules III, IV, & V

Requirements

  • An oral prescription from a practitioner is routinely acceptable.
  • Must be promptly reduced to writing by the pharmacist.

📝MPJE Tip

Know the difference: Oral CIIs are emergency-only. Oral CIII-Vs are routinely acceptable if the pharmacist writes them down immediately.

True electronic prescriptions for controlled substances (EPCS) are allowed for all schedules but require stringent, DEA-certified software systems for both the prescriber and the pharmacy.

Schedule II

Requirements

  • Permitted if the practitioner's and pharmacy's software systems meet all specific DEA security and certification requirements (Part 1311).

Schedules III, IV, & V

Requirements

  • Permitted if the practitioner's and pharmacy's software systems meet all specific DEA security and certification requirements (Part 1311).

📝MPJE Tip for All Schedules

DO ensure any system used for EPCS is DEA compliant. DON'T confuse a computer-generated fax with a true, compliant electronic prescription. They are not the same.