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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Dana Westberg, CPhT