As of Jan. 1, controlled substance security prescription forms must include a new, unique serial number in a format approved by the Department of Justice. However, the new requirement does not allow for a transition period during which providers would be allowed to use the previously approved form, and those who do not have access to the new forms have been forced to choose between denying care and risking action against their licenses.
The new law was enacted as part of a comprehensive bill package to address the opioid crisis.
To mitigate the issues prescribers are experiencing during the transition, the California Board of Pharmacy has recommended that no enforcement action be taken before July 1. In its letter outlining this recommendation, the board also provided several alternatives pharmacists may consider if the required form is not available. Further, Assemblymember Evan Low, the law’s author, has requested that the Department of Justice issue regulations delaying implementation of the requirement until issues can be resolved.
More information is available in a notice from the Medical Board of California and a joint statement from the medical board, pharmacy board and justice department. Hospitals that have questions should direct them to BJ Bartleson, CHA’s vice president, nursing and clinical services.