In the article “A Proactive Approach to Controlled Substance Refills” [November/December 2010], the authors seem to describe proactive clerical prescription processing, but retroactive clinical medication monitoring. In the process, they misrepresent the new prescriptions they recommend writing without associated clinical assessments as prescription “refills.” The confusion created by the use of this terminology has substantial medicolegal and clinical ramifications, beginning with the fact that prescription refills for schedule II drugs are illegal: “The issuance of refills for a schedule II controlled substance is prohibited by law.”1
Drug Enforcement Administration regulations allow doctors to prescribe a sequence of up to three 30-day prescriptions in a single office visit. Following this simple, clinically proactive method would altogether eliminate the need for patients to pick up monthly “refills” from non-clinical intermediaries.
Issuing a sequence of three time-delineated prescriptions during a single visit, as Dr. Teichman suggests, is certainly an acceptable option for providers. The method described in our article allows each separate prescription to be written and given to the patient in the time frame when it will be used, rather than giving multiple prescriptions to the patient at one time.
Our program of providing a separate prescription each month allows tighter surveillance with urine toxicology screening and physician oversight, which we have found beneficial. Our method does not involve refilling controlled substances on a single prescription, which, as Dr. Teichman mentions, is illegal for schedule II drugs.