(Part I) Compounding and Ordering CII Drugs – New Regulations

As you may have heard the CA board of Pharmacy has developed new regulations that go into effect January 1st, 2017. It is pivotal that we as a business keep you, our clients, updated on these changes. The majority of the new regulations will not affect your day to day interation with our pharmacy, but some of the updates will change the way you order compounded medications. In an effort to get out ahead of the changes and keep our veterinary partners informed, we will be releasing a 3 part newsletter series on the changing regulations.

Controlled Medications

One of the areas in which we encounter the most confusion, is the legal ordering process for CII medications. There have been a lot of questions about the process as clinics have adjusted to an increase in prescriptions for drugs like Hydrocodone. We thought that it would be a good idea to kick off the newsletter series with discussion on the correct way to order CII medications, along with the proper forms and prescription pads which need to be used.

First we will break down the process of ordering a CII medication for a patient.

CA Board of Pharmacy requires that all prescribers writing prescriptions for CII medications do so on a tamper resistant security prescription pad. These pads can only be obtained from a printer approved by the Office of the Attorney General. A list of approved printers can be found here: https://oag.ca.gov/security-printers/approved-list

 

 ciipad

Step by step process in prescribing a CII medication
Step 1: Order a CII, tamper resistant security prescription pad. These pads can only be purchased from a printer approved by the Office of the Attorney General. You may find the list of approved printers here: https://oag.ca.gov/security-printers/approved-list
Step 2: Make sure all of the following information is pre-printed on the prescription pad
-Prescriber Name
-Prescriber Address
-Prescriber Phone Number
-Prescriber DEA and CA License Numbers
-The Phrase "Prescription is Void if the
Number of drugs prescribed is not noted"
printed on the bottom
-A check box next to the name of each
prescriber when the form lists multiple
prescribers
Note, the name and DEA number of the prescriber writing the prescription must be pre-printed on the prescription pad. It may not be written in after the fact. Even if a prescriber is new to a practice, all of their information needs to be pre-printed.

Filling out the prescriptions
Step 3: Fill out all necessary information - patient name, owner name, contact information, address and DOB
Step 4: Properly spell the drug name (very important, even a misspelling can void a prescription)
Step 5: Check, circle, or indicate the number of prescriptions on the pad (label them 1, 2, 3, etc)
Step 6: Quantity of each prescription (written and indicated by check the quantity range box)
Step 7: Instructions
Step 8: Lastly, and most importantly the prescriber must sign and date the prescription. Both must be in the prescriber's handwriting and must be in the same color ink.
Step 9: Once completed, mail the prescription to our pharmacy. The actual hard copy is needed before we are able to dispense the medication.

222form

checklist

Difference in 222 form and CII prescription pad
The DEA 222 form, also known as a "triplicate form," is used for ordering commercially available medications for in house use. They are not used for compounded medications. If you are needing to prescribe a compounded CII medication, please refer to "step by step process in prescribing a CII medication"

Step by step instruction in properly filling out a 222 form
Step 1: Correctly fill out the top portion of form with the correct supplier name, address, city & state (for example: Golden Gate Veterinary Compounding Pharmacy, 1525 E. Francisco Blvd, Suite 2b, San Rafael, CA 94901)
Step 2: Date the form
Step 3: Write the correct number of packages per medication, list the size/quantity, and the correct spelling of the medication and desired strength
Step 4: At the bottom of the table, make sure to list the number of lines used (for example, if you are ordering 3 medications, and have listed 3 medications, the number of lines used would be 3)
Step 5: Prescriber's signature adjacent to the number of lines used box.
Step 6: Once completed, mail the 222 form to our pharmacy. The actual hard copy is needed before we are able to dispense the medication.