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Prescribing and Reporting Rules for Controlled Substances Coming

Supplemental Materials:

Prescribers of controlled substances should be aware of these two upcoming requirements in state law.

Updated Prescription Pad Security Requirements

Starting January 1, 2021, pads used to write and fill prescriptions for controlled substances are required to have a 12-character serial number, a corresponding barcode, and other security features required by Assembly Bill 149. California-approved security printers have been issuing these prescription pads since the beginning of 2020.

Prescribers who do not possess these prescription pads are encouraged to place an order as soon as possible from a Security Prescription Printer approved by the Department of Justice. Doing so will help ensure you receive compliant prescription pads in a timely manner.

Starting January 1, 2021, except for limited emergency situations , pharmacists will be unable to fill a controlled substances prescription that is not on a compliant form. To reduce potential negative impacts to patients, we would like to remind prescribers that they may continue to issue an oral or electronically transmitted prescription for Schedule III, IV, and V controlled substances, as authorized by Health and Safety Code section 11164 (b)(1). We encourage prescribers to work with pharmacists, as appropriate, to address the needs of patients in possession of noncompliant forms.

Further, prescriptions issued electronically are not subject to the security features related to paper forms and if you are currently submitting prescriptions electronically, the Board recommends you to continue doing so.

You may wish to consider having some paper prescription forms in the office that are compliant with AB 149, should there be a technological impediment that prevents you from submitting the prescription electronically, or if another exception applies.

Additional guidance available: AB 149 - New requirements for controlled substances prescription forms

Please note: The Board would also like to remind you that by January 1, 2022, all prescriptions must be submitted electronically, with a few exemptions, pursuant to Assembly Bill 2789 of 2018.

Revised Reporting Requirements for Controlled Substances

Beginning January 1, 2021, the dispensing of a controlled substance must be reported to the Controlled Substance Utilization Review and Evaluation System (CURES) within one working day after the medication is released to the patient or the patient's representative. Previously, the deadline to report was seven days after dispensing.

Further, this law requires reporting the dispensing of Schedule V drugs, in addition to Schedules II, III, and IV. This requirement applies to pharmacists and prescribers who dispense controlled substances.

Additional guidance available: AB 528 - New requirements for reporting dispensed controlled substances