OK, in order to KIND OF understand this, let me give some background on the three major controlled substances. They are basically based on three times per month with medication checks after. Not doing those is at your own peril and loses EASY MONEY.
Opioids Class II -- can only send one month at a time (best to do 28 so their next script is not due on a weekend. We try to make it Monday through Thursday to give that extra Friday for those with a million excuses. These CANNOT have refills or have multiple scripts sent. They require a new PMP review (simple now that it is in NewCrop and probably much simpler if it is now within AC in v11). We do two, document the hell out of them especially if they need an exemption code for over 100 MME, then require a med check either by telemed or in person. Here we document like crazy.
ADHD meds Class II -- generally these can be sent so they are good for three months. You can actually send more, but the last script has to be filled within 90 days of the time it was written, so three is the best. Many doctors' offices send one month at a time with a lot of extra phone calls for us and the pharmacy, plus it makes the med checks hard to keep up with. By sending three scripts at a time, it builds in the three-month med check. It is absolutely STUPID you cannot write for 2 refills. Same outcome, just it is safer and easier for all concerned. Now, to make matters even crazier but better for those who don't accept Medicaid, private insurance allows 90 days supply of ADHD meds as long as documented on the script. Confused? If not, you aced the Kreb's cycle. In the days before EPCS, we printed three scripts with a do not fill before such as such a date. This, of course, led to some of the funniest excuses. We took no excuse except documented house fires. Seriously. It is difficult to keep track of who is what insurance and who changes so we just do the three months' worth.
Benzodiazepines Class III-IV -- OK, this is fun, because you can write for Ativan and put 2 refills. Three month med check. Good for patient monitoring and MONEY. You can write for up to five refills. THESE CAN BE FAXED OR CALLED IN LEGALLY, but a pharmacist can disallow that if they don't feel comfortable.
So, based on that, opioids and benzos are relatively simple.
It is the ADHDs that are STUPID. Refills should be allowed, period. But, at the very least, they have to stick with the three at a time, which changes the fact that my MA could set up 9 ADHD scripts, and I just did a telemed, documented and did 50-factor authentication (because we all know patients on Adderall have access to an EMR and authy. But, we need the code -- mine is 2437.
Now, first understand DEA came up with this new rule only they didn't bother to let prescribers or pharmacists know and, worse, why. The only way we knew was when we went to send three, we got a messages stating we could only send one at a time and to delete the other two. This not NewCrop or Allscripts or any individual company. In fact, my contact at NC argued this and was furious about it. She emailed me just after I found out, saying oh my god, Bert is going to flip out. I am on their pseud-advisory board.
Now, as physicians, let us try to figure out DEA's here. OK, they could have have a beef with doctors and want to pissed them off. Doubtful. They could just not like the idea of sending three of the same CII scripts at the same time, By the way, you can send Concerta 36 mg and Concerta 54 mg at the same time. The computers can only differentiate EXACT CIIs for now. So, I thought about it and I put two and two together and got five. Why five. Because that is how stupid the DEA is. The ONLY thing that would make sense in their reasoning, although it will make documentation and our work MUCH harder if we do three-month med checks (remember good for documentation, PMP and MONEY). It sounds like what they meant by you can't SEND three controlled at a time, they meant you can only send ONE month at a time like the opioids. That would make sense to some degree.
All in all, it will make things much more difficult, less safe, more work on both the prescribers, patients and pharmacies (it is hard enough to get along with pharmacies as it is).
What is needed and I would be the first one to volunteer would be quarterly meeting with prescribers, pharmacists and the DEA. I am not saying we can stop the DEA. But, at least the pharmacists and PCPs could talk and the pharmacists and PCPs could get to see who they don't get along with.
We could also mention to the DEA that rather than worry about prescriptions that are being sent to people who supposedly need them and are being monitored by a electronic system which is damned near fool proof. That just maybe they could use their time to look at Heroin, laced-fentanyl, drugs coming over the border and the Al Pacino's of the world. "Say hello to my little friend."
I myself am contacting the DEA's top people as well as reaching out to our governor. This is bullshit. And for those who talk about well opioids are done the exact same way, well maybe it is reversed in offices with old patients, but we have six patients over 100 MME (easy to keep track of) and over 50 patients on ADHD drugs. Oh and quite a few on Klonopin. Covid made a lot of patients anxious beyond Atarax, Intuniv, Buspar and Prozac.
