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Update: DEA Reschedules Hydrocodone Combination Products from Schedule III to Schedule II

Update: Drug Enforcement Agency Reschedules Hydrocodone Combination Products from Schedule III to Schedule II
(Posted 9/17/14)

This is an update to the membership email that was sent on August 27, 2014.

The Drug Enforcement Agency (DEA) rescheduled Hydrocodone Combination Products (HCPs) such as Vicodin ®, Lortab ®, and Hycodan®  from Schedule III to the more-restrictive Schedule II, effective October 6, 2014. Dentists not already holding a Schedule II permit need to contact both the DEA (http://www.deadiversion.usdoj.gov/drugreg/index.html); Click on “Registration Changes”) and Texas Department of Public Safety (DPS) (www.txdps.state.tx.us/RSD/ControlledSubstances/csforms.htm) to request a schedule change/modification in prescribing authority. Be sure that both the DEA and DPS registrations have the same name and address.

Texas dentists writing prescriptions for Schedule II drugs, and not using an approved E-prescribing process, must write the prescription on either a special “triplicate” form or an “Official CII Prescription Form” issued by the DPS. The DPS updated their regulations in October 2013 to allow E-prescribing capability for Schedule II prescriptions (37 Texas Administrative Code §13.72 Prescriptions). Any triplicate prescription forms containing the dentist’s correct DPS registration number remain valid and may be used until the supply is depleted.

Official DPS prescription forms may be ordered from http://www.txdps.state.tx.us/internetforms/Forms/RSD-19.pdf. Although the DPS strives to complete official prescription form orders in less than 3 weeks, the typical processing time is 4 weeks. At this time, the DPS does not have the ability to process orders or payments online. To ensure the fastest processing time, the dentist’s name needs to match the name on the DPS registration, the address needs to match the address on the DPS registration, and the dentist’s DPS and DEA numbers need to match those on file with each agency. Dentists making changes in the DPS registry need to submit the modification form before ordering the official prescription form. The revised modification form can be faxed to 512-424-5799.

The DEA and DPS are permitting legitimate HCP prescriptions issued before October 6, 2014, to be refilled until April 8, 2015, if the prescription authorizes refills.

According to the Texas Controlled Substances Act, in emergencies, a prescribing dentist may telephone a Schedule II prescription into the pharmacy, as long as the quantity prescribed and the dispensed amount is limited to the amount adequate to treat the patient during the emergency period. The prescribing dentist must then provide the pharmacist a written, signed official prescription within 7 days.


DEA Reschedules Hydrocodone Combination Products 
(Posted 8/27/14)

The Drug Enforcement Agency (DEA) issued a final rule on Friday, August 22, 2014, rescheduling hydrocodone combination products (HCPs) from Schedule III to Schedule II of the Controlled Substance Act. The new rule takes effect October 6, 2014 — 45 days from publication. HCPs are pharmaceutical drugs containing hydrocodone in certain combinations with other drugs. Common names include: Vicodin ®, Lortab ®, Hycodan ®, and several generics.

Dentists not already holding a Schedule II permit need to contact both the DEA (www.deadiversion.usdoj.gov/drugreg/index.html; Click on “Registration Changes”) and Texas Department of Public Safety (DPS) to request a schedule change in prescribing authority. Be sure that both the DEA and DPS registrations have the same address.

Dentists may write prescriptions for Schedule II drugs on either a special “triplicate” form or an “official” prescription form. Any triplicate prescriptions that are in use are still valid prescriptions and may be used until the supply is depleted. The official forms are issued by the Texas Department of Public Safety to prescribers. Go to the Official Prescription Forms webpage on the DPS website for information on ordering the official form.

Schedule II controlled substances require a written prescription that must be signed by the prescribing dentist and refills may not be authorized for any HCP prescriptions. However, prescribers may issue multiple prescriptions authorizing a patient to receive a total of up to a 90-day supply of HCPs, provided certain regulatory requirements are met. The DEA is also permitting legitimate HCP prescriptions issued before October 6, 2014, to be refilled until April 8, 2015, if the prescription authorizes refills.