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Serial Numbers on Prescription Pads for Controlled Substances Now Required – California Law

With the passage of Assembly Bill (AB) 1753 during the last legislative session, beginning January 1, 2019, prescription forms for controlled substances must be printed with a unique serial number to help standardize the tracking of the prescription pads. This information will also be linked to corresponding records in California’s Controlled Substance Utilization Review and Evaluation System (CURES) 2.0.

California law requires prescribers of any Schedule II through V controlled substance to obtain and use tamper-resistant prescription forms ordered only from state-approved security printers. An updated list of California-approved security prescription printers which meet the new requirements can be viewed or downloaded from OSHA Review’s website.

Transitioning to the New Forms

AB 1753 did not include any transition or grandfathering period to allow for continued use of old controlled substance security prescription forms on or after January 1, 2019. Therefore, pharmacists could be looking for the unique serial numbers on controlled substance security prescription forms for controlled substances starting January 1, 2019, and could potentially deny noncompliant prescribers.

However, due to the late notice by the California Department of Justice (DOJ) to provide any guidance on the new requirements, in a letter dated December 27, 2018 and sent to California licensed pharmacists, the California Board of Pharmacy stated it would “not make enforcement a priority” until July 1, 2019, if pharmacists choose to fill prescriptions written on security prescription forms that were compliant prior to January 1, but are not compliant with the new serialization requirement.

The Pharmacy Board urged pharmacists to exercise their best professional judgment when handling these situations, to determine if it is in the best interest of the patient or public health or safety to nonetheless fill such prescriptions.

Action Needed

DEA-registered prescribers are encouraged to utilize the new forms that include the serial numbers for all prescriptions of controlled substances. Additionally, during this unofficial transition period, prescribers who continue to use noncompliant prescription forms for controlled substances may want to keep a copy of the Board of Pharmacy’s advisory letter for communication with pharmacists, if necessary.

Since 1992, OSHA Review, Inc. has provided dental professionals with comprehensive programs to support regulatory compliance and infection control. We are a registered continuing education provider in the state of California, specializing in Dental Practice Act, infection control, and OSHA training.

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