Audit Risks with Schedule II Laddered Prescriptions

Pharmacies receiving laddered Schedule II prescriptions must be aware of the DEA requirements and potential audit risks. Missing these requirements can lead to Federal law violations and PBM audit recoupment.

Laddered prescriptions are multiple prescriptions written on the same date for current and future fills. Since Schedule II prescriptions cannot be refilled, the DEA has allowed prescribers to issue multiple prescriptions totaling up to a 90-day supply if all requirements have been met.

Requirements included in 21 CFR §1306.12:

Prescription must be issued for a legitimate medical purpose
Other than the initial prescription, the prescriber must include written instructions of the earliest fill date
Prescriber must believe that issuing multiple prescriptions is not an increased risk of diversion or abuse
Prescriptions must comply with all applicable state laws and regulations

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Medication prescribed in a laddered series may not exceed a total of 90 days
Check for exact fill dates on prescriptions other than the one for immediate use
Claims billed prior to the earliest fill date can lead to recoupment
Pharmacies should not alter Schedule II prescriptions unless their state law explicitly allows the alteration
- With laddered C-IIs, it’s likely best to request new prescriptions if changes are necessary
See our October 2021 Newsline, Self-Audit Series #9: Controlled Substance Prescriptions
See our September 2022 Newsline, Use and Posting Guidance Documents by DEA-What’s Changed with Controlled Substance Annotations?
See our November 2022 Newsline, What’s Changed with C-II Prescription Annotations? (September Follow-Up)

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Dana Westberg, CPhT

Analyst at PAAS National^®

As a Certified Pharmacy Technician at PAAS, I am here to assist and provide you with pre- and post-audit advice. I can also provide product and billing information.

I attended Madison College in nearby Madison, WI (PAAS headquarters are in the Madison suburb of Stoughton). Prior to coming to work at PAAS, I worked as a Certified Pharmacy Technician in a retail setting for 25+ years. Pharmacy has been my life’s work.

Helping our members have a successful audit experience is very rewarding. Celebrating with them, when PAAS often helps generate positive post-audit results, is the best part of my work.

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