Due to widespread abuse of Hydrocodone Combination Products (HCPs) such as Lorcet, Lortab, Norco and Vicoprofen the DEA has been on a mission to reclassify all dosage concentrations as schedule II controlled substances. Currently (and prior to this change) straight hydrocodone and dose concentrations greater than 15 mg we already assigned to schedule II, which dentists typically do not use.
This effort by the DEA has been a long time a coming. Efforts to reclassify Hydrocodone Combination Products (HCPs) have been underway since 2008. Discussions between the U.S. Health and Human Services and the DEA and public comments contributed to the effort.
On Friday, August 22, 2014 the DEA published the DEA administrator’s decision to re-classify ALL HCPs from schedule III to schedule II. One might ask why this matters to dentists who have the authority by the DEA and state controlled substance authority to write prescriptions for, administer, and dispense schedule II controlled substances. I often hear dentists say don’t write scripts for schedule IIs. Perhaps that was true – until now.
In Texas and California schedule IIs cannot be phoned in to the pharmacy, they must be handwritten on a tamper-resistant triplicate prescription form or electronically submitted to the pharmacy using an e-prescribe program. Currently, practitioners in Minnesota (and soon those in New York) can only prescribe controlled substances by e-prescription. I will expound on e-prescribing in a moment.
I anticipate some of you will scramble to identify and prescribe alternatives, so you don’t have to deal with the onerous task of handwriting scripts. Many dentists I have talked with prescribe 800 mg Motrin or tramadol (Ultram) as a controlled substance alternative. You’re the clinician do your research and make your own determinations.
You might recall that a couple months ago the DEA announced tramadol was assigned to the classification of schedule IV. This went into effect in early August. This means that dentists (orthodontists) did not need to have a DEA registration write scripts for tramadol until now. Be sure to pass this along to your orthodontist friends. The going rate for DEA registrations is, as you know, $712 for three years.
In recent years many dentists have become accustomed to preparing and printing scripts using their dental software. It is convenient in that you can quickly create scripts, but the system also creates a historical record of scripts you write, which (controlled substance or not) is important for accurately documenting provided care and follow up for your patients. You will no longer be allowed print and hand your patient software generated scripts for HCPs using your dental software after October 6, 2014.
It is important to note that Texas DPS and the DEA are cracking down on registrants for failing to secure and keep secure their script pads at all times. I often encounter pads lying around dental offices. No, it is not acceptable that the pads are lying on the dentist’s desk in his or her private office, they must be under lock and key just like controlled drugs that might be in the office.
Failure to secure prescription pads is punishable by fines up to $5000 by DPS. Unrestricted access to EPCS programs is also punishable as a violation of state and federal law. The Dental Board, DPS and DEA communicate with one another. When a practitioner finds themselves in trouble with one of those agencies for a drug-related violation they usually find themselves in trouble with all three agencies.
As I mentioned earlier I spoke with one of my contacts at the DPS prescription program. My source told me dentists need to get on the ball and order their triplicate pads ASAP. I learned that even if dentists and physicians order their pads today they may not receive their pads by October 6th when HCPs officially become schedule IIs. In Texas the only approved-vendor to purchase prescription pads is Texas DPS.
To facilitate your order you must write or type your order on your letterhead. (Need help? Email me and I can send you a sample form letter) Write a check for the amount of your order and send it by certified mail (every time you send anything to the government in connection with your professional status you should do by certified mail). Prescription pads are $9.00 per pad of 100 scripts.
For those dentists who have received the EHR incentive grant EPCS fulfills a stage II Meaningful Use (MU) requirement. Remember that for stage two MU you are required to report for a 90 day period for continued qualification for your grant.
In summary, hydrocodone combinations products (HCPs) were reclassified as schedule II controlled substances. In Texas dentists are required to use triplicate prescriptions pads that can only order from DPS or use a DEA approved Electronic Prescriptions for Controlled Substances (EPCS) service, some of which integrate with some dental software programs. The effective date of this change is 10/06/2014.
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