New Policies Regarding Written Prescriptions
The Department of Justice has implemented new policies regarding written prescriptions for controlled substances, in a continued effort to combat drug abuse. As of January 1, 2019, all written prescriptions for Schedule II, III, IV, or V controlled substances must be done so on an approved security prescription form that is compliant with their new policies.
We know that for many of you, this may seem like deja vu. Unfortunately, this is a separate issue from what was experienced last year with the non-compliant printers. This is a legislated change that went into effect on January 1, 2019. We at Golden Gate VCP wanted to bring this to your attention, as it impacts our ability to fill controlled substances from written prescriptions, especially Schedule II controlled substances, which require a written prescription each time they are prescribed. Prescription pads printed prior to January 1, 2019 are likely no longer in compliance with state regulations, and will have to be replaced. Please take a moment to contact your prescription printer to obtain new, approved forms. Alternatively, you may find a list of approved prescription pad printers at https://www.oag.ca.gov/security-printers/approved-list. Please choose from an authorized printer that has an asterisk* and states that it is a serial # compliant printer.
We understand that these changes may cause some confusion, and that many of you may have some additional questions. Below we have included a brief list of expected frequently asked questions, to help provide some guidance. We appreciate your continued business with Golden Gate Veterinary Compounding Pharmacy If you have any questions, please feel free to reach out to our staff, who will be more than willing to provide assistance.
1) When do these new form requirements take into effect?
Answer: As of January 1, 2019, all written prescriptions for controlled substances must be written on the newly approved security prescription forms. However, the Board of Pharmacy understands that there was limited advance notice of these changes, and that prescribers need some time to procure new forms. They have stated that enforcement of these changes will not be of a high priority until July 1, 2019. As of July 1, 2019, we will no longer be able to take any prescriptions for controlled substances on outdated security prescription forms. We ask that all prescribers obtain new security prescription forms as soon as possible, and if a controlled substance prescription needs to be written for a patient, please call the pharmacy for guidance.
2) After January 1, am I still able to prescribe controlled substances if I do not have an authorized security prescription form?
Answer: Yes, for most controlled substances. Any Schedule III, schedule IV, or schedule V prescription may be phoned into our pharmacy at (415) 455-5590, and we can transcribe it as a verbal prescription. This is the preferred method for these types of medications, as it eliminates the issue regarding whether or not a security prescription form is valid. For schedule II controlled substances filled prior to July 1, 2019, please contact the pharmacy before you submit a written prescription, so that we may verify our ability to fill from it. On or after July, 1, 2019, we will no longer be able to receive and fill from non-compliant security prescription forms.
3) Where can find a compliant security form printer to order new forms?
Answer: The Office of the Attorney General has compiled a list of approved vendors for security prescription forms, which can be found at https://www.oag.ca.gov/security-printers/approved-list. All new prescription pads must have all required security features previously required, plus a valid serial number, unique to each prescription.
4) What are other ways prescriptions for controlled substances can be filled by Golden Gate Veterinary Compounding Pharmacy?
Answer: At any time, prescriptions for Schedule III, Schedule IV, and Schedule V controlled substances may be called in directly to the pharmacy, where we can verbally authorize the prescription. For Schedule II controlled substances, such as hydrocodone, which require a physical hard copy prescription to be presented to the pharmacy, you may still be able to use your previously compliant security prescription form until July 1, 2019. We ask that you contact us via phone or fax before sending the prescription, so that we may confirm whether or not we will be able to fill the prescription.
5) What does a valid serial number look like?
Answer: The serial number will be labeled on the prescription form for easy identification. The serial number format is as follows: three alphas, followed by six numerics, followed by one alpha, followed by five numerics. The format can be seen below.