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Frequently Asked Questions for Pharmacists on Changes to Schedule II Controlled Substances


CHANGES TO SCHEDULE 2 CONTROLLED SUBSTANCE PRESCRIPTIONS.  Board staff have received many calls and emails inquiring about the continued ability for pharmacists to make certain changes to Schedule II prescriptions in consultation with the prescriber. The source of the angst appears to be as follows:

A 2019 presidential executive order required all federal agencies to review and consolidate various informal guidance documents.  As a result of this review, the federal Drug Enforcement Administration removed informal guidance on its website that concerned changes to Schedule II prescriptions.  The National Association of Chain Drug Stores issued a letter describing a private phone call with unnamed DEA officials, during which NACDS interpreted their statements as an “implication” that a Schedule II prescriptions may not be altered or changed in any way by a pharmacist.

Whatever was said on this phone call, Board of Pharmacy staff disagrees that a pharmacist may not make certain changes to a Schedule II prescription in consultation with the prescriber.  The mere fact that informal guidance was withdrawn does not mean that the conduct the informal guidance described is now “illegal.”  Nor do statements by individual DEA officials on a private phone all establish a “policy” of any sort.  Accordingly, Board staff view the longstanding statement linked above concerning changes to Schedule II prescriptions as appropriate.  If DEA issues any formal guidance or proposed rulemaking change on this matter, Board staff will update. 

*UPDATE* The DEA has issued the following statement that pharmacists may continue to follow the guidance of their state boards of pharmacy on this matter:




Q: What changes can be made to Schedule II Prescriptions?

A: After consulting with the prescribing practitioner (you must speak directly to the practitioner, not his/her agent), the pharmacist may modify or add the following:

  • date of issue – may be added but not changed;
  • patient’s address;
  • drug strength;
  • drug dosage form;
  • drug quantity – may be modified in conjunction with change in strength only, not to exceed the original total dosage prescribed; and
  • directions for use.

A pharmacist may never change the name of the drug (except to generic when appropriate), name of the patient, or the signature of the practitioner.



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