PAAS has been seeing an increase in audits for ‘laddered’ controlled substance prescriptions. A ladder prescription is a Schedule II controlled substance written as multiple prescriptions issued on the same date. This allows for fewer prescriber office visits where refills are not allowed by DEA regulations. They are commonly written for routine ADHD and pain medications.
The DEA has specific regulations for the issuance of multiple prescriptions for Schedule 2 controlled substances in 21 CFR §1306.12. The requirements include:
- Each prescription must be for a legitimate medical purpose
- Prescriptions may be for a total of up to a 90-day supply
- Prescriptions must have written instructions indicating the earliest date each prescription may be filled
- Except the first prescription if intended to be filled immediately
- Prescriber determines that issuing multiple prescriptions does not increase risk of diversion or abuse
- Prescriptions must comply with any additional state laws or regulations