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Frequently Asked Questions

Pharmacy PSA

IMPORTANT: Updated frequently asked questions for Prescribers and Dispensers

No. There is no limit on writing a prescription for a patient who not experiencing pain. Section 456.44(5), F.S., only applies a 3-day or 7-day supply limit to prescriptions for treatment of acute pain.

July 1, 2018, except for the provisions related to certificates of exemption for Pain Management Clinics, which are effective January 1, 2019.

Allopathic Physician, Osteopathic Physician, Dentist, Podiatrist, Certified Optometrist, ARNP, and PA.

"Acute pain" is the normal, predicted, physiological, and time-limited response to an adverse chemical, thermal, or mechanical stimulus associated with surgery, trauma, or acute illness. It does not include pain related to cancer, terminal conditions, pain treated with palliative care, or traumatic injuries with an Injury Severity Score of 9 or greater.

A prescription of a Schedule II opioid to alleviate acute paid may not exceed a 3-day supply, codifying the CDC guideline for the treatment of acute pain.

A prescribing practitioner may prescribe up to a 7-day supply if:
(1) the physician determines it is medically necessary; (2) indicates "acute pain exception" on the prescription; AND (3) documents the justification for deviating from the 3-day supply limit in the patient's medical record.

Exceptions to acute pain limits: (1) cancer, (2) a terminal condition, (3) pain treated with palliative care, and (4) a traumatic injury with an Injury Severity Score of 9 or higher. There is NO prescribing limit for these conditions.

A progressive disease or medical or surgical condition that causes significant functional impairment, is not considered by the treating physician to be reversible without the administration of life-sustaining procedures, and will result in death within 1 year after diagnosis if the condition runs its normal course.

The provision of relief for symptoms related to an incurable, progressive illness or injury.

An Injury Severity Score is a method for describing trauma patients with multiple injuries and evaluating emergency care. The score ranges from 1 to 75. See Trauma.org for more information.

When prescribing opioids to a patient with an Injury Severity Score of 9 or higher, the prescriber must also prescribe an emergency opioid antagonist.

The prescriber must indicate "nonacute pain" on the prescription.

This requirement applies to prescriptions for chronic pain, as well as those conditions listed as being excluded from the definition of acute pain.

Yes, each board has disciplinary guidelines that set forth the penalties.

Board specific disciplinary guidelines are found on their board specific sites through flhealthsource.gov.

A dispensing practitioner is a practitioner authorized by law to prescribe drugs who may dispense such drugs to her or his patients in the regular course of her or his practice in compliance with Section 465.0276, F.S. Dispensing practitioners may include: alleopathic physicians, osteopathic physicians, dentists, optometrists, podiatrists, ARNPs and PAs.

Yes, in compliance with applicable law.

For the treatment of pain other than acute pain, a practitioner must indicate "NONACUTE PAIN" on the prescription. Additionally, for the treatment of pain related to a traumatic injury with an Injury Severity Score of 9 or greater, a dispensing practitioner must concurrently prescribe an emergency opioid antagonist, as defined in s. 381.887(1), F.S.

A registered dispensing practitioner may dispense a 3-day supply of controlled substances for the treatment of acute pain. A 7-day supply may be dispensed if certain criteria in Section 456.44(5)(a), F.S. are met. Additionally, for a controlled substance listed in Schedule III, the amount dispensed may not exceed a 14-day supply.

The law regarding the limitations on controlled substances did not change in this area. A dispensing practitioner may not allow for the dispensing of a controlled substance listed in Schedule II or Schedule III more than 14 days after the performance of a surgical procedure.

A registered dispensing practitioner may dispense controlled substances listed in Schedule II or Schedule III which have been approved by the United States Food and Drug Administration for the purpose of treating opiate addictions, including, but not limited to, buprenorphine and buprenorphine combination products, by a practitioner authorized under 21 U.S.C. s. 823, as amended, to the practitioner's own patients for the medication-assisted treatment of opiate addiction.

Before dispensing a controlled substance to a person not known to the practitioner, he or she must require the person purchasing, receiving, or otherwise acquiring the controlled substance to present valid photographic identification or other verification of his or her identity.

Proper identification" means an identification that is issued by a state or the Federal Government containing the person's photograph, printed name, and signature or a document considered acceptable under 8 C.F.R. s. 274a.2(b)(1)(v)(A) and (B).

If the person does not have proper identification, the pharmacist may verify the validity of the prescription and the identity of the patient with the prescriber or his or her authorized agent. Verification of health plan eligibility through a real-time inquiry or adjudication system is also considered to be proper identification.

No

Continuing Education FAQs

January 31, 2019

All prescribing practitioners registered with the United States Drug Enforcement Agency and authorized to prescribe controlled substances must complete the continuing education course.

2 hours

January 31, 2019 AND at each subsequent licensure renewal.

The course taken by January 31, 2019 will count toward the first renewal cycle. For further questions regarding your renewal period, check with your respective board.

Yes. Advanced Registered Nurse Practitioners and Physician Assistants have a separate 3-hour CE requirement for controlled substances, and are exempted from the new two-hour course.

The course must be offered by a statewide professional association of physicians in this state that is accredited to provide educational activities designated for the American Medical Association Physician’s Recognition Award Category I Credit or the American Osteopathic Category 1-A continuing medical education requirement.

The Florida Medical Association, Florida Osteopathic Medical Association, Florida Academy of Family Physicians, and Florida College of Emergency Physicians.

Yes

https://www.cebroker.com

Go to the course search, under “All Subjects,” click the drop down menu.

Click on “Prescribing Controlled Substances.”

Once the courses are approved, then the Prescribing Controlled Substances tab will lead to registration for the available CE courses.

Drop Down Menu on cebroker.com.

The course may be taken live or through distance learning from any one of the four approved providers.

DOH may not renew the license of a prescriber who fails to complete this continuing education requirement.

If yes, you are required to take the mandatory CE course.
Prescription Drug Monitoring FAQs

Dispensing practitioners are required to report to the Prescription Drug Monitoring Program (PDMP) system each time a controlled substance is dispensed to a patient, as soon thereafter as possible, but no later than close of business the day after the prescription is dispensed – unless an extension or exemption is approved by the Department of Health.

A prescriber or dispenser or a designee of a prescriber or dispenser must consult the PDMP system to review a patient's controlled substance dispensing history before prescribing or dispensing a controlled substance for a patient age 16 or older.

A prescriber or dispenser or a designee of a prescriber or dispenser does not have to consult the PDMP system when prescribing or dispensing a nonopioid controlled substance listed in Schedule V of s. 893.03 or 21 U.S.C. 812.

The duty to consult the system does not apply when the system:

  • Is determined by the department to be nonoperational; or
  • Cannot be accessed by the prescriber or dispenser or a designee of the prescriber or dispenser because of a temporary technological or electrical failure

 

A prescriber or dispenser or designee of a prescriber or dispenser who does not consult the PDMP system shall document the reason he or she did not consult the system in the patient's medical record or prescription record and shall not prescribe or dispense greater than a 3-day supply of a controlled substance to the patient.

A person who willfully and knowingly fails to report the dispensing of a controlled substance as required by this legislation commits a misdemeanor of the first degree, punishable as provided in s. 775.082 or s. 775.083, F.S. Further, the department shall issue a nondisciplinary citation to any prescriber or dispenser who fails to consult the system as required by this subsection for an initial offense. Each subsequent offense is subject to disciplinary action pursuant to s. 456.073, F.S.

If you do not prescribe any controlled substances you are not required to register with or consult E-FORCSE.

You are still authorized to register. You can view your patients' controlled substance dispensing histories and use the "MyRx" report to see if any controlled substances are being dispensed using your DEA number.

Prescribers, dispensers and their designees may register for access at https://florida.pmpaware.net

To review a patient's controlled substance dispensing history prior to prescribing or dispensing a controlled substance in Schedules II-V, as defined in section 893.03, F.S., for patients age 16 and older.

 

  • If the PDMP system is not operational as determined by DOH, or
  • The PDMP cannot be accessed by the prescribing/dispensing practitioner due to a temporary technological or electrical failure or
  • When prescribing or dispensing a nonopioid Schedule V drug or
  • The patient is less than 16 years of age

 

The prescribing/dispensing practitioner must document in the patient’s record the reason the PDMP was not consulted and may prescribe or dispense no more than a 3-day supply of a controlled substance.

Yes

The DOH will issue a non-disciplinary citation for the initial offense.

Any subsequent offense will result in disciplinary action against the prescribing/dispensing practitioner’s license. Disciplinary guidelines are individually established by the appropriate licensing board.

A prescription for a controlled substance listed in Schedule II may not be refilled. However, the dispensing practitioner must consult the PDMP before filling a prescription for a controlled substance listed in Schedule III, Schedule IV, or Schedule V.

The statute does not provide any guidance on how far in advance the PDMP may be consulted. Please refer to your Board's website for further guidance.

The PDMP must be consulted each time a prescription for a controlled substance is written.

Schedules II, III, IV, and V drugs must all be reported.

Yes. Any schedule V controlled substances that are non-opioids and prescriptions dispensed to patients under the age of 16.

 

  1. The telephone number of the person for whom the prescription was written, in addition to the name, address, and date of birth the prescriber currently inputs;
  2. Whether the prescription is an initial prescription or a refill, and the number of refills prescribed;
  3. The name of the individual picking up the controlled substance prescription and the type and issuer of the identification provided; and
  4. The pharmacy's DOH-issued permit number or the dispensing practitioner’s DOH-issued license number

 

Yes. Information that is more than 4 years old.

The Department has published a notice of rule development and will be amending Rule 64K-1.002, FAC . The PDMP will continue to accept submissions in the ASAP 2009 version 4.2 and the new 4.2a standard for one year from the effective date of the rule.

 

  1. The pharmacy permit number or the dispensing health care practitioner's license number.
  2. The name of the individual picking up the controlled substance prescription and type and issuer of the identification provided.

 

A prescribing practitioner can put in refills on a Schedule 3, 4, and 5 substance if the PDMP is consulted before the original prescribing. A prescriber is required to consult the PDMP on new prescriptions. However, a dispenser must consult the PDMP on the new prescription and on each subsequent refill.

Back
Frequently Asked Questions

Pharmacy PSA

IMPORTANT: Updated frequently asked questions for Prescribers and Dispensers

No. There is no limit on writing a prescription for a patient who not experiencing pain. Section 456.44(5), F.S., only applies a 3-day or 7-day supply limit to prescriptions for treatment of acute pain.

All prescribing practitioners registered with the United States Drug Enforcement Agency and authorized to prescribe controlled substances must complete the continuing education course.

Yes

July 1, 2018, except for the provisions related to certificates of exemption for Pain Management Clinics, which are effective January 1, 2019.

January 31, 2019

Allopathic Physician, Osteopathic Physician, Dentist, Podiatrist, Certified Optometrist, ARNP, and PA.

"Acute pain" is the normal, predicted, physiological, and time-limited response to an adverse chemical, thermal, or mechanical stimulus associated with surgery, trauma, or acute illness. It does not include pain related to cancer, terminal conditions, pain treated with palliative care, or traumatic injuries with an Injury Severity Score of 9 or greater.

A prescription of a Schedule II opioid to alleviate acute paid may not exceed a 3-day supply, codifying the CDC guideline for the treatment of acute pain.

A prescribing practitioner may prescribe up to a 7-day supply if:
(1) the physician determines it is medically necessary; (2) indicates "acute pain exception" on the prescription; AND (3) documents the justification for deviating from the 3-day supply limit in the patient's medical record.

Exceptions to acute pain limits: (1) cancer, (2) a terminal condition, (3) pain treated with palliative care, and (4) a traumatic injury with an Injury Severity Score of 9 or higher. There is NO prescribing limit for these conditions.

A progressive disease or medical or surgical condition that causes significant functional impairment, is not considered by the treating physician to be reversible without the administration of life-sustaining procedures, and will result in death within 1 year after diagnosis if the condition runs its normal course.

The provision of relief for symptoms related to an incurable, progressive illness or injury.

An Injury Severity Score is a method for describing trauma patients with multiple injuries and evaluating emergency care. The score ranges from 1 to 75. See Trauma.org for more information.

When prescribing opioids to a patient with an Injury Severity Score of 9 or higher, the prescriber must also prescribe an emergency opioid antagonist.

The prescriber must indicate "nonacute pain" on the prescription.

This requirement applies to prescriptions for chronic pain, as well as those conditions listed as being excluded from the definition of acute pain.

Yes, each board has disciplinary guidelines that set forth the penalties.

Board specific disciplinary guidelines are found on their board specific sites through flhealthsource.gov.

All prescribing practitioners registered with the United States Drug Enforcement Agency and authorized to prescribe controlled substances must complete the continuing education course.

2 hours

January 31, 2019 AND at each subsequent licensure renewal.

The course taken by January 31, 2019 will count toward the first renewal cycle. For further questions regarding your renewal period, check with your respective board.

Yes. Advanced Registered Nurse Practitioners and Physician Assistants have a separate 3-hour CE requirement for controlled substances, and are exempted from the new two-hour course.

The course must be offered by a statewide professional association of physicians in this state that is accredited to provide educational activities designated for the American Medical Association Physician’s Recognition Award Category I Credit or the American Osteopathic Category 1-A continuing medical education requirement.

The Florida Medical Association, Florida Osteopathic Medical Association, Florida Academy of Family Physicians, and Florida College of Emergency Physicians.

Yes

https://www.cebroker.com

Go to the course search, under “All Subjects,” click the drop down menu.

Click on “Prescribing Controlled Substances.”

Once the courses are approved, then the Prescribing Controlled Substances tab will lead to registration for the available CE courses.

Drop Down Menu on cebroker.com.

The course may be taken live or through distance learning from any one of the four approved providers.

DOH may not renew the license of a prescriber who fails to complete this continuing education requirement.

A dispensing practitioner is a practitioner authorized by law to prescribe drugs who may dispense such drugs to her or his patients in the regular course of her or his practice in compliance with Section 465.0276, F.S. Dispensing practitioners may include: alleopathic physicians, osteopathic physicians, dentists, optometrists, podiatrists, ARNPs and PAs.

Yes, in compliance with applicable law.

For the treatment of pain other than acute pain, a practitioner must indicate "NONACUTE PAIN" on the prescription. Additionally, for the treatment of pain related to a traumatic injury with an Injury Severity Score of 9 or greater, a dispensing practitioner must concurrently prescribe an emergency opioid antagonist, as defined in s. 381.887(1), F.S.

A registered dispensing practitioner may dispense a 3-day supply of controlled substances for the treatment of acute pain. A 7-day supply may be dispensed if certain criteria in Section 456.44(5)(a), F.S. are met. Additionally, for a controlled substance listed in Schedule III, the amount dispensed may not exceed a 14-day supply.

The law regarding the limitations on controlled substances did not change in this area. A dispensing practitioner may not allow for the dispensing of a controlled substance listed in Schedule II or Schedule III more than 14 days after the performance of a surgical procedure.

A registered dispensing practitioner may dispense controlled substances listed in Schedule II or Schedule III which have been approved by the United States Food and Drug Administration for the purpose of treating opiate addictions, including, but not limited to, buprenorphine and buprenorphine combination products, by a practitioner authorized under 21 U.S.C. s. 823, as amended, to the practitioner's own patients for the medication-assisted treatment of opiate addiction.

Before dispensing a controlled substance to a person not known to the practitioner, he or she must require the person purchasing, receiving, or otherwise acquiring the controlled substance to present valid photographic identification or other verification of his or her identity.

Proper identification" means an identification that is issued by a state or the Federal Government containing the person's photograph, printed name, and signature or a document considered acceptable under 8 C.F.R. s. 274a.2(b)(1)(v)(A) and (B).

If the person does not have proper identification, the pharmacist may verify the validity of the prescription and the identity of the patient with the prescriber or his or her authorized agent. Verification of health plan eligibility through a real-time inquiry or adjudication system is also considered to be proper identification.

No

Dispensing practitioners are required to report to the Prescription Drug Monitoring Program (PDMP) system each time a controlled substance is dispensed to a patient, as soon thereafter as possible, but no later than close of business the day after the prescription is dispensed – unless an extension or exemption is approved by the Department of Health.

A prescriber or dispenser or a designee of a prescriber or dispenser must consult the PDMP system to review a patient's controlled substance dispensing history before prescribing or dispensing a controlled substance for a patient age 16 or older.

A prescriber or dispenser or a designee of a prescriber or dispenser does not have to consult the PDMP system when prescribing or dispensing a nonopioid controlled substance listed in Schedule V of s. 893.03 or 21 U.S.C. 812.

The duty to consult the system does not apply when the system:

  • Is determined by the department to be nonoperational; or
  • Cannot be accessed by the prescriber or dispenser or a designee of the prescriber or dispenser because of a temporary technological or electrical failure

 

A prescriber or dispenser or designee of a prescriber or dispenser who does not consult the PDMP system shall document the reason he or she did not consult the system in the patient's medical record or prescription record and shall not prescribe or dispense greater than a 3-day supply of a controlled substance to the patient.

A person who willfully and knowingly fails to report the dispensing of a controlled substance as required by this legislation commits a misdemeanor of the first degree, punishable as provided in s. 775.082 or s. 775.083, F.S. Further, the department shall issue a nondisciplinary citation to any prescriber or dispenser who fails to consult the system as required by this subsection for an initial offense. Each subsequent offense is subject to disciplinary action pursuant to s. 456.073, F.S.

If you do not prescribe any controlled substances you are not required to register with or consult E-FORCSE.

You are still authorized to register. You can view your patients' controlled substance dispensing histories and use the "MyRx" report to see if any controlled substances are being dispensed using your DEA number.

Prescribers, dispensers and their designees may register for access at https://florida.pmpaware.net

To review a patient's controlled substance dispensing history prior to prescribing or dispensing a controlled substance in Schedules II-V, as defined in section 893.03, F.S., for patients age 16 and older.

 

  • If the PDMP system is not operational as determined by DOH, or
  • The PDMP cannot be accessed by the prescribing/dispensing practitioner due to a temporary technological or electrical failure or
  • When prescribing or dispensing a nonopioid Schedule V drug or
  • The patient is less than 16 years of age

 

The prescribing/dispensing practitioner must document in the patient’s record the reason the PDMP was not consulted and may prescribe or dispense no more than a 3-day supply of a controlled substance.

Yes

The DOH will issue a non-disciplinary citation for the initial offense.

Any subsequent offense will result in disciplinary action against the prescribing/dispensing practitioner’s license. Disciplinary guidelines are individually established by the appropriate licensing board.

A prescription for a controlled substance listed in Schedule II may not be refilled. However, the dispensing practitioner must consult the PDMP before filling a prescription for a controlled substance listed in Schedule III, Schedule IV, or Schedule V.

The statute does not provide any guidance on how far in advance the PDMP may be consulted. Please refer to your Board's website for further guidance.

The PDMP must be consulted each time a prescription for a controlled substance is written.

Schedules II, III, IV, and V drugs must all be reported.

Yes. Any schedule V controlled substances that are non-opioids and prescriptions dispensed to patients under the age of 16.

 

  1. The telephone number of the person for whom the prescription was written, in addition to the name, address, and date of birth the prescriber currently inputs;
  2. Whether the prescription is an initial prescription or a refill, and the number of refills prescribed;
  3. The name of the individual picking up the controlled substance prescription and the type and issuer of the identification provided; and
  4. The pharmacy's DOH-issued permit number or the dispensing practitioner’s DOH-issued license number

 

Yes. Information that is more than 4 years old.

The Department has published a notice of rule development and will be amending Rule 64K-1.002, FAC . The PDMP will continue to accept submissions in the ASAP 2009 version 4.2 and the new 4.2a standard for one year from the effective date of the rule.

 

  1. The pharmacy permit number or the dispensing health care practitioner's license number.
  2. The name of the individual picking up the controlled substance prescription and type and issuer of the identification provided.

 

A prescribing practitioner can put in refills on a Schedule 3, 4, and 5 substance if the PDMP is consulted before the original prescribing. A prescriber is required to consult the PDMP on new prescriptions. However, a dispenser must consult the PDMP on the new prescription and on each subsequent refill.

Back
Frequently Asked Questions

Pharmacy PSA

IMPORTANT: Updated frequently asked questions for Prescribers and Dispensers

No. There is no limit on writing a prescription for a patient who not experiencing pain. Section 456.44(5), F.S., only applies a 3-day or 7-day supply limit to prescriptions for treatment of acute pain.

January 1, 2019

A pain management clinic that claims an exemption from the registration requirement.

 

  1. The name or names under which the applicant does business;
  2. The address at which the pain management clinic is located;
  3. The specific exemption that the applicant is claiming, along with supporting documentation; AND
  4. Any other information DOH deems necessary

 

No

DOH must approve or deny an application for a certificate of exemption within 30 days after receipt.

Each certificate must be renewed biennially, but the initial certificate may be issued for up to three years to allow DOH to establish renewal cycles.

A pain management clinic must prominently display its certificate of exemption and make it available to DOH or the applicable board upon request.

Each certificate of exemption is valid only for the applicant, owners, licenses, registrations, certifications, and services provided under the specific exemption claimed.

No

A new application must be submitted and a new certificate of exemption must be issued if the clinic changes its address.

60 days

Notify the DOH within 3 days and either register as a pain management clinic or cease operation.

Yes, for non-acute pain. A pain management clinic must follow 456.44 F.S. Controlled substance prescribing.

For the treatment of pain other than acute pain, a prescriber must indicate “NONACUTE PAIN” on a prescription for an opioid drug listed as a Schedule II controlled substance in s. 893.03 or 21 U.S.C. s. 812.

July 1, 2018, except for the provisions related to certificates of exemption for Pain Management Clinics, which are effective January 1, 2019.

January 31, 2019

Allopathic Physician, Osteopathic Physician, Dentist, Podiatrist, Certified Optometrist, ARNP, and PA.

"Acute pain" is the normal, predicted, physiological, and time-limited response to an adverse chemical, thermal, or mechanical stimulus associated with surgery, trauma, or acute illness. It does not include pain related to cancer, terminal conditions, pain treated with palliative care, or traumatic injuries with an Injury Severity Score of 9 or greater.

A prescription of a Schedule II opioid to alleviate acute paid may not exceed a 3-day supply, codifying the CDC guideline for the treatment of acute pain.

A prescribing practitioner may prescribe up to a 7-day supply if:
(1) the physician determines it is medically necessary; (2) indicates "acute pain exception" on the prescription; AND (3) documents the justification for deviating from the 3-day supply limit in the patient's medical record.

Exceptions to acute pain limits: (1) cancer, (2) a terminal condition, (3) pain treated with palliative care, and (4) a traumatic injury with an Injury Severity Score of 9 or higher. There is NO prescribing limit for these conditions.

A progressive disease or medical or surgical condition that causes significant functional impairment, is not considered by the treating physician to be reversible without the administration of life-sustaining procedures, and will result in death within 1 year after diagnosis if the condition runs its normal course.

The provision of relief for symptoms related to an incurable, progressive illness or injury.

An Injury Severity Score is a method for describing trauma patients with multiple injuries and evaluating emergency care. The score ranges from 1 to 75. See Trauma.org for more information.

When prescribing opioids to a patient with an Injury Severity Score of 9 or higher, the prescriber must also prescribe an emergency opioid antagonist.

The prescriber must indicate "nonacute pain" on the prescription.

This requirement applies to prescriptions for chronic pain, as well as those conditions listed as being excluded from the definition of acute pain.

Yes, each board has disciplinary guidelines that set forth the penalties.

Board specific disciplinary guidelines are found on their board specific sites through flhealthsource.gov.

All prescribing practitioners registered with the United States Drug Enforcement Agency and authorized to prescribe controlled substances must complete the continuing education course.

2 hours

January 31, 2019 AND at each subsequent licensure renewal.

The course taken by January 31, 2019 will count toward the first renewal cycle. For further questions regarding your renewal period, check with your respective board.

Yes. Advanced Registered Nurse Practitioners and Physician Assistants have a separate 3-hour CE requirement for controlled substances, and are exempted from the new two-hour course.

The course must be offered by a statewide professional association of physicians in this state that is accredited to provide educational activities designated for the American Medical Association Physician’s Recognition Award Category I Credit or the American Osteopathic Category 1-A continuing medical education requirement.

(1) The Florida Medical Association, (2) Florida Osteopathic Medical Association, (3) Florida Academy of Family Physicians, (4) Florida College of Emergency Physicians, (5) Baptist Health South Florida, (6) InforMed, and (7) Florida Psychiatric Society.

Yes

https://www.cebroker.com

Go to the course search, under “All Subjects,” click the drop down menu.

Click on “Prescribing Controlled Substances.”

Once the courses are approved, then the Prescribing Controlled Substances tab will lead to registration for the available CE courses.

Drop Down Menu on cebroker.com.

The course may be taken live or through distance learning from any one of the four approved providers.

DOH may not renew the license of a prescriber who fails to complete this continuing education requirement.

A dispensing practitioner is a practitioner authorized by law to prescribe drugs who may dispense such drugs to her or his patients in the regular course of her or his practice in compliance with Section 465.0276, F.S. Dispensing practitioners may include: alleopathic physicians, osteopathic physicians, dentists, optometrists, podiatrists, ARNPs and PAs.

Yes, in compliance with applicable law.

For the treatment of pain other than acute pain, a practitioner must indicate "NONACUTE PAIN" on the prescription. Additionally, for the treatment of pain related to a traumatic injury with an Injury Severity Score of 9 or greater, a dispensing practitioner must concurrently prescribe an emergency opioid antagonist, as defined in s. 381.887(1), F.S.

A registered dispensing practitioner may dispense a 3-day supply of controlled substances for the treatment of acute pain. A 7-day supply may be dispensed if certain criteria in Section 456.44(5)(a), F.S. are met. Additionally, for a controlled substance listed in Schedule III, the amount dispensed may not exceed a 14-day supply.

The law regarding the limitations on controlled substances did not change in this area. A dispensing practitioner may not allow for the dispensing of a controlled substance listed in Schedule II or Schedule III more than 14 days after the performance of a surgical procedure.

A registered dispensing practitioner may dispense controlled substances listed in Schedule II or Schedule III which have been approved by the United States Food and Drug Administration for the purpose of treating opiate addictions, including, but not limited to, buprenorphine and buprenorphine combination products, by a practitioner authorized under 21 U.S.C. s. 823, as amended, to the practitioner's own patients for the medication-assisted treatment of opiate addiction.

Before dispensing a controlled substance to a person not known to the practitioner, he or she must require the person purchasing, receiving, or otherwise acquiring the controlled substance to present valid photographic identification or other verification of his or her identity.

Proper identification" means an identification that is issued by a state or the Federal Government containing the person's photograph, printed name, and signature or a document considered acceptable under 8 C.F.R. s. 274a.2(b)(1)(v)(A) and (B).

If the person does not have proper identification, the pharmacist may verify the validity of the prescription and the identity of the patient with the prescriber or his or her authorized agent. Verification of health plan eligibility through a real-time inquiry or adjudication system is also considered to be proper identification.

No

Dispensing practitioners are required to report to the Prescription Drug Monitoring Program (PDMP) system each time a controlled substance is dispensed to a patient, as soon thereafter as possible, but no later than close of business the day after the prescription is dispensed – unless an extension or exemption is approved by the Department of Health.

A prescriber or dispenser or a designee of a prescriber or dispenser must consult the PDMP system to review a patient's controlled substance dispensing history before prescribing or dispensing a controlled substance for a patient age 16 or older.

A prescriber or dispenser or a designee of a prescriber or dispenser does not have to consult the PDMP system when prescribing or dispensing a nonopioid controlled substance listed in Schedule V of s. 893.03 or 21 U.S.C. 812.

The duty to consult the system does not apply when the system:

  • Is determined by the department to be nonoperational; or
  • Cannot be accessed by the prescriber or dispenser or a designee of the prescriber or dispenser because of a temporary technological or electrical failure

 

A prescriber or dispenser or designee of a prescriber or dispenser who does not consult the PDMP system shall document the reason he or she did not consult the system in the patient's medical record or prescription record and shall not prescribe or dispense greater than a 3-day supply of a controlled substance to the patient.

A person who willfully and knowingly fails to report the dispensing of a controlled substance as required by this legislation commits a misdemeanor of the first degree, punishable as provided in s. 775.082 or s. 775.083, F.S. Further, the department shall issue a nondisciplinary citation to any prescriber or dispenser who fails to consult the system as required by this subsection for an initial offense. Each subsequent offense is subject to disciplinary action pursuant to s. 456.073, F.S.

If you do not prescribe any controlled substances you are not required to register with or consult E-FORCSE.

You are still authorized to register. You can view your patients' controlled substance dispensing histories and use the "MyRx" report to see if any controlled substances are being dispensed using your DEA number.

Prescribers, dispensers and their designees may register for access at https://florida.pmpaware.net

To review a patient's controlled substance dispensing history prior to prescribing or dispensing a controlled substance in Schedules II-V, as defined in section 893.03, F.S., for patients age 16 and older.

 

  • If the PDMP system is not operational as determined by DOH, or
  • The PDMP cannot be accessed by the prescribing/dispensing practitioner due to a temporary technological or electrical failure or
  • When prescribing or dispensing a nonopioid Schedule V drug or
  • The patient is less than 16 years of age

 

The prescribing/dispensing practitioner must document in the patient’s record the reason the PDMP was not consulted and may prescribe or dispense no more than a 3-day supply of a controlled substance.

Yes

The DOH will issue a non-disciplinary citation for the initial offense.

Any subsequent offense will result in disciplinary action against the prescribing/dispensing practitioner’s license. Disciplinary guidelines are individually established by the appropriate licensing board.

A prescription for a controlled substance listed in Schedule II may not be refilled. However, the dispensing practitioner must consult the PDMP before filling a prescription for a controlled substance listed in Schedule III, Schedule IV, or Schedule V.

The statute does not provide any guidance on how far in advance the PDMP may be consulted. Please refer to your Board's website for further guidance.

The PDMP must be consulted each time a prescription for a controlled substance is written.

Schedules II, III, IV, and V drugs must all be reported.

Yes. Any schedule V controlled substances that are non-opioids and prescriptions dispensed to patients under the age of 16.

 

  1. The telephone number of the person for whom the prescription was written, in addition to the name, address, and date of birth the prescriber currently inputs;
  2. Whether the prescription is an initial prescription or a refill, and the number of refills prescribed;
  3. The name of the individual picking up the controlled substance prescription and the type and issuer of the identification provided; and
  4. The pharmacy's DOH-issued permit number or the dispensing practitioner’s DOH-issued license number

 

Yes. Information that is more than 4 years old.

The Department has published a notice of rule development and will be amending Rule 64K-1.002, FAC . The PDMP will continue to accept submissions in the ASAP 2009 version 4.2 and the new 4.2a standard for one year from the effective date of the rule.

 

  1. The pharmacy permit number or the dispensing health care practitioner's license number.
  2. The name of the individual picking up the controlled substance prescription and type and issuer of the identification provided.

 

A prescribing practitioner can put in refills on a Schedule 3, 4, and 5 substance if the PDMP is consulted before the original prescribing. A prescriber is required to consult the PDMP on new prescriptions. However, a dispenser must consult the PDMP on the new prescription and on each subsequent refill.

Back
Frequently Asked Questions

Pharmacy PSA

IMPORTANT: Updated frequently asked questions for Prescribers and Dispensers

No. There is no limit on writing a prescription for a patient who not experiencing pain. Section 456.44(5), F.S., only applies a 3-day or 7-day supply limit to prescriptions for treatment of acute pain.

No, only Advanced Practice Registered Nurses are required to complete 3 hours of continuing education on the topic of controlled substances.

Three hours of continuing education must be completed each biennium on the Safe and Effective Prescription of Controlled Substances. The courses must be offered by a statewide professional association of physicians in this state accredited to provide educational activities designated for the American Medical Association Physician's Recognition Award Category 1 credit, the American Nurses Credentialing Center, the American Association of Nurse Anesthetists, or the American Association of Nurse Practitioners and may be offered in a distance learning format.

July 1, 2018, except for the provisions related to certificates of exemption for Pain Management Clinics, which are effective January 1, 2019.

January 31, 2019

Allopathic Physician, Osteopathic Physician, Dentist, Podiatrist, Certified Optometrist, ARNP, and PA.

"Acute pain" is the normal, predicted, physiological, and time-limited response to an adverse chemical, thermal, or mechanical stimulus associated with surgery, trauma, or acute illness. It does not include pain related to cancer, terminal conditions, pain treated with palliative care, or traumatic injuries with an Injury Severity Score of 9 or greater.

A prescription of a Schedule II opioid to alleviate acute paid may not exceed a 3-day supply, codifying the CDC guideline for the treatment of acute pain.

A prescribing practitioner may prescribe up to a 7-day supply if:
(1) the physician determines it is medically necessary; (2) indicates "acute pain exception" on the prescription; AND (3) documents the justification for deviating from the 3-day supply limit in the patient's medical record.

Exceptions to acute pain limits: (1) cancer, (2) a terminal condition, (3) pain treated with palliative care, and (4) a traumatic injury with an Injury Severity Score of 9 or higher. There is NO prescribing limit for these conditions.

A progressive disease or medical or surgical condition that causes significant functional impairment, is not considered by the treating physician to be reversible without the administration of life-sustaining procedures, and will result in death within 1 year after diagnosis if the condition runs its normal course.

The provision of relief for symptoms related to an incurable, progressive illness or injury.

An Injury Severity Score is a method for describing trauma patients with multiple injuries and evaluating emergency care. The score ranges from 1 to 75. See Trauma.org for more information.

When prescribing opioids to a patient with an Injury Severity Score of 9 or higher, the prescriber must also prescribe an emergency opioid antagonist.

The prescriber must indicate "nonacute pain" on the prescription.

This requirement applies to prescriptions for chronic pain, as well as those conditions listed as being excluded from the definition of acute pain.

Yes, each board has disciplinary guidelines that set forth the penalties.

Board specific disciplinary guidelines are found on their board specific sites through flhealthsource.gov.

All prescribing practitioners registered with the United States Drug Enforcement Agency and authorized to prescribe controlled substances must complete the continuing education course.

3 hours

January 31, 2019 AND at each subsequent licensure renewal.

The course taken by January 31, 2019 will count toward the first renewal cycle. For further questions regarding your renewal period, check with your respective board.

Yes. Advanced Registered Nurse Practitioners and Physician Assistants have a separate 3-hour CE requirement for controlled substances, and are exempted from the new two-hour course.

The 3 hour course must be offered by a statewide professional association of physicians in this state accredited to provide educational activities designated for the American Medical Association Physician’s Recognition Award Category 1 credit, the American Nurses Credentialing Center, the American Association of Nurse Anesthetists, or the American Association of Nurse Practitioners.

Yes

https://www.cebroker.com

Go to the course search, under “All Subjects,” click the drop down menu.

Click on “Prescribing Controlled Substances.”

Once the courses are approved, then the Prescribing Controlled Substances tab will lead to registration for the available CE courses.

Drop Down Menu on cebroker.com.

The course may be taken live or through distance learning from any one of the four approved providers.

DOH may not renew the license of a prescriber who fails to complete this continuing education requirement.

A dispensing practitioner is a practitioner authorized by law to prescribe drugs who may dispense such drugs to her or his patients in the regular course of her or his practice in compliance with Section 465.0276, F.S. Dispensing practitioners may include: alleopathic physicians, osteopathic physicians, dentists, optometrists, podiatrists, ARNPs and PAs.

Yes, in compliance with applicable law.

For the treatment of pain other than acute pain, a practitioner must indicate "NONACUTE PAIN" on the prescription. Additionally, for the treatment of pain related to a traumatic injury with an Injury Severity Score of 9 or greater, a dispensing practitioner must concurrently prescribe an emergency opioid antagonist, as defined in s. 381.887(1), F.S.

A registered dispensing practitioner may dispense a 3-day supply of controlled substances for the treatment of acute pain. A 7-day supply may be dispensed if certain criteria in Section 456.44(5)(a), F.S. are met. Additionally, for a controlled substance listed in Schedule III, the amount dispensed may not exceed a 14-day supply.

The law regarding the limitations on controlled substances did not change in this area. A dispensing practitioner may not allow for the dispensing of a controlled substance listed in Schedule II or Schedule III more than 14 days after the performance of a surgical procedure.

A registered dispensing practitioner may dispense controlled substances listed in Schedule II or Schedule III which have been approved by the United States Food and Drug Administration for the purpose of treating opiate addictions, including, but not limited to, buprenorphine and buprenorphine combination products, by a practitioner authorized under 21 U.S.C. s. 823, as amended, to the practitioner's own patients for the medication-assisted treatment of opiate addiction.

Before dispensing a controlled substance to a person not known to the practitioner, he or she must require the person purchasing, receiving, or otherwise acquiring the controlled substance to present valid photographic identification or other verification of his or her identity.

Proper identification" means an identification that is issued by a state or the Federal Government containing the person's photograph, printed name, and signature or a document considered acceptable under 8 C.F.R. s. 274a.2(b)(1)(v)(A) and (B).

If the person does not have proper identification, the pharmacist may verify the validity of the prescription and the identity of the patient with the prescriber or his or her authorized agent. Verification of health plan eligibility through a real-time inquiry or adjudication system is also considered to be proper identification.

No

Dispensing practitioners are required to report to the Prescription Drug Monitoring Program (PDMP) system each time a controlled substance is dispensed to a patient, as soon thereafter as possible, but no later than close of business the day after the prescription is dispensed – unless an extension or exemption is approved by the Department of Health.

A prescriber or dispenser or a designee of a prescriber or dispenser must consult the PDMP system to review a patient's controlled substance dispensing history before prescribing or dispensing a controlled substance for a patient age 16 or older.

A prescriber or dispenser or a designee of a prescriber or dispenser does not have to consult the PDMP system when prescribing or dispensing a nonopioid controlled substance listed in Schedule V of s. 893.03 or 21 U.S.C. 812.

The duty to consult the system does not apply when the system:

  • Is determined by the department to be nonoperational; or
  • Cannot be accessed by the prescriber or dispenser or a designee of the prescriber or dispenser because of a temporary technological or electrical failure

 

A prescriber or dispenser or designee of a prescriber or dispenser who does not consult the PDMP system shall document the reason he or she did not consult the system in the patient's medical record or prescription record and shall not prescribe or dispense greater than a 3-day supply of a controlled substance to the patient.

A person who willfully and knowingly fails to report the dispensing of a controlled substance as required by this legislation commits a misdemeanor of the first degree, punishable as provided in s. 775.082 or s. 775.083, F.S. Further, the department shall issue a nondisciplinary citation to any prescriber or dispenser who fails to consult the system as required by this subsection for an initial offense. Each subsequent offense is subject to disciplinary action pursuant to s. 456.073, F.S.

If you do not prescribe any controlled substances you are not required to register with or consult E-FORCSE.

You are still authorized to register. You can view your patients' controlled substance dispensing histories and use the "MyRx" report to see if any controlled substances are being dispensed using your DEA number.

Prescribers, dispensers and their designees may register for access at https://florida.pmpaware.net

To review a patient's controlled substance dispensing history prior to prescribing or dispensing a controlled substance in Schedules II-V, as defined in section 893.03, F.S., for patients age 16 and older.

 

  • If the PDMP system is not operational as determined by DOH, or
  • The PDMP cannot be accessed by the prescribing/dispensing practitioner due to a temporary technological or electrical failure or
  • When prescribing or dispensing a nonopioid Schedule V drug or
  • The patient is less than 16 years of age

 

The prescribing/dispensing practitioner must document in the patient’s record the reason the PDMP was not consulted and may prescribe or dispense no more than a 3-day supply of a controlled substance.

Yes

The DOH will issue a non-disciplinary citation for the initial offense.

Any subsequent offense will result in disciplinary action against the prescribing/dispensing practitioner’s license. Disciplinary guidelines are individually established by the appropriate licensing board.

A prescription for a controlled substance listed in Schedule II may not be refilled. However, the dispensing practitioner must consult the PDMP before filling a prescription for a controlled substance listed in Schedule III, Schedule IV, or Schedule V.

The statute does not provide any guidance on how far in advance the PDMP may be consulted. Please refer to your Board's website for further guidance.

The PDMP must be consulted each time a prescription for a controlled substance is written.

Schedules II, III, IV, and V drugs must all be reported.

Yes. Any schedule V controlled substances that are non-opioids and prescriptions dispensed to patients under the age of 16.

 

  1. The telephone number of the person for whom the prescription was written, in addition to the name, address, and date of birth the prescriber currently inputs;
  2. Whether the prescription is an initial prescription or a refill, and the number of refills prescribed;
  3. The name of the individual picking up the controlled substance prescription and the type and issuer of the identification provided; and
  4. The pharmacy's DOH-issued permit number or the dispensing practitioner’s DOH-issued license number

 

Yes. Information that is more than 4 years old.

The Department has published a notice of rule development and will be amending Rule 64K-1.002, FAC . The PDMP will continue to accept submissions in the ASAP 2009 version 4.2 and the new 4.2a standard for one year from the effective date of the rule.

 

  1. The pharmacy permit number or the dispensing health care practitioner's license number.
  2. The name of the individual picking up the controlled substance prescription and type and issuer of the identification provided.

 

A prescribing practitioner can put in refills on a Schedule 3, 4, and 5 substance if the PDMP is consulted before the original prescribing. A prescriber is required to consult the PDMP on new prescriptions. However, a dispenser must consult the PDMP on the new prescription and on each subsequent refill.

Back
Frequently Asked Questions

Pharmacy PSA

IMPORTANT: Updated frequently asked questions for Prescribers and Dispensers

No. There is no limit on writing a prescription for a patient who not experiencing pain. Section 456.44(5), F.S., only applies a 3-day or 7-day supply limit to prescriptions for treatment of acute pain.

No, only licensed certified optometrists who are authorized to prescribed controlled substances are required to take a 2-hour controlled substance course by an approved provider by January 31, 2019, and each subsequent biennial renewal thereafter.

July 1, 2018, except for the provisions related to certificates of exemption for Pain Management Clinics, which are effective January 1, 2019.

January 31, 2019

Allopathic Physician, Osteopathic Physician, Dentist, Podiatrist, Certified Optometrist, ARNP, and PA.

"Acute pain" is the normal, predicted, physiological, and time-limited response to an adverse chemical, thermal, or mechanical stimulus associated with surgery, trauma, or acute illness. It does not include pain related to cancer, terminal conditions, pain treated with palliative care, or traumatic injuries with an Injury Severity Score of 9 or greater.

A prescription of a Schedule II opioid to alleviate acute paid may not exceed a 3-day supply, codifying the CDC guideline for the treatment of acute pain.

A prescribing practitioner may prescribe up to a 7-day supply if:
(1) the physician determines it is medically necessary; (2) indicates "acute pain exception" on the prescription; AND (3) documents the justification for deviating from the 3-day supply limit in the patient's medical record.

Exceptions to acute pain limits: (1) cancer, (2) a terminal condition, (3) pain treated with palliative care, and (4) a traumatic injury with an Injury Severity Score of 9 or higher. There is NO prescribing limit for these conditions.

A progressive disease or medical or surgical condition that causes significant functional impairment, is not considered by the treating physician to be reversible without the administration of life-sustaining procedures, and will result in death within 1 year after diagnosis if the condition runs its normal course.

The provision of relief for symptoms related to an incurable, progressive illness or injury.

An Injury Severity Score is a method for describing trauma patients with multiple injuries and evaluating emergency care. The score ranges from 1 to 75. See Trauma.org for more information.

When prescribing opioids to a patient with an Injury Severity Score of 9 or higher, the prescriber must also prescribe an emergency opioid antagonist.

The prescriber must indicate "nonacute pain" on the prescription.

This requirement applies to prescriptions for chronic pain, as well as those conditions listed as being excluded from the definition of acute pain.

Yes, each board has disciplinary guidelines that set forth the penalties.

Board specific disciplinary guidelines are found on their board specific sites through flhealthsource.gov.

All prescribing practitioners registered with the United States Drug Enforcement Agency and authorized to prescribe controlled substances must complete the continuing education course.

2 hours

January 31, 2019 AND at each subsequent licensure renewal.

The course taken by January 31, 2019 will count toward the first renewal cycle. For further questions regarding your renewal period, check with your respective board.

Yes. Advanced Registered Nurse Practitioners and Physician Assistants have a separate 3-hour CE requirement for controlled substances, and are exempted from the new two-hour course.

The course must be offered by a statewide professional association of physicians in this state that is accredited to provide educational activities designated for the American Medical Association Physician’s Recognition Award Category I Credit or the American Osteopathic Category 1-A continuing medical education requirement.

The Florida Medical Association, Florida Osteopathic Medical Association, Florida Academy of Family Physicians, and Florida College of Emergency Physicians.

Yes

https://www.cebroker.com

Go to the course search, under “All Subjects,” click the drop down menu.

Click on “Prescribing Controlled Substances.”

Once the courses are approved, then the Prescribing Controlled Substances tab will lead to registration for the available CE courses.

Drop Down Menu on cebroker.com.

The course may be taken live or through distance learning from any one of the approved providers.

DOH may not renew the license of a prescriber who fails to complete this continuing education requirement.

A dispensing practitioner is a practitioner authorized by law to prescribe drugs who may dispense such drugs to her or his patients in the regular course of her or his practice in compliance with Section 465.0276, F.S. Dispensing practitioners may include: alleopathic physicians, osteopathic physicians, dentists, optometrists, podiatrists, ARNPs and PAs.

Yes, in compliance with applicable law.

For the treatment of pain other than acute pain, a practitioner must indicate "NONACUTE PAIN" on the prescription. Additionally, for the treatment of pain related to a traumatic injury with an Injury Severity Score of 9 or greater, a dispensing practitioner must concurrently prescribe an emergency opioid antagonist, as defined in s. 381.887(1), F.S.

A registered dispensing practitioner may dispense a 3-day supply of controlled substances for the treatment of acute pain. A 7-day supply may be dispensed if certain criteria in Section 456.44(5)(a), F.S. are met. Additionally, for a controlled substance listed in Schedule III, the amount dispensed may not exceed a 14-day supply.

The law regarding the limitations on controlled substances did not change in this area. A dispensing practitioner may not allow for the dispensing of a controlled substance listed in Schedule II or Schedule III more than 14 days after the performance of a surgical procedure.

A registered dispensing practitioner may dispense controlled substances listed in Schedule II or Schedule III which have been approved by the United States Food and Drug Administration for the purpose of treating opiate addictions, including, but not limited to, buprenorphine and buprenorphine combination products, by a practitioner authorized under 21 U.S.C. s. 823, as amended, to the practitioner's own patients for the medication-assisted treatment of opiate addiction.

Before dispensing a controlled substance to a person not known to the practitioner, he or she must require the person purchasing, receiving, or otherwise acquiring the controlled substance to present valid photographic identification or other verification of his or her identity.

Proper identification" means an identification that is issued by a state or the Federal Government containing the person's photograph, printed name, and signature or a document considered acceptable under 8 C.F.R. s. 274a.2(b)(1)(v)(A) and (B).

If the person does not have proper identification, the pharmacist may verify the validity of the prescription and the identity of the patient with the prescriber or his or her authorized agent. Verification of health plan eligibility through a real-time inquiry or adjudication system is also considered to be proper identification.

No

Dispensing practitioners are required to report to the Prescription Drug Monitoring Program (PDMP) system each time a controlled substance is dispensed to a patient, as soon thereafter as possible, but no later than close of business the day after the prescription is dispensed – unless an extension or exemption is approved by the Department of Health.

A prescriber or dispenser or a designee of a prescriber or dispenser must consult the PDMP system to review a patient's controlled substance dispensing history before prescribing or dispensing a controlled substance for a patient age 16 or older.

A prescriber or dispenser or a designee of a prescriber or dispenser does not have to consult the PDMP system when prescribing or dispensing a nonopioid controlled substance listed in Schedule V of s. 893.03 or 21 U.S.C. 812.

The duty to consult the system does not apply when the system:

  • Is determined by the department to be nonoperational; or
  • Cannot be accessed by the prescriber or dispenser or a designee of the prescriber or dispenser because of a temporary technological or electrical failure

 

A prescriber or dispenser or designee of a prescriber or dispenser who does not consult the PDMP system shall document the reason he or she did not consult the system in the patient's medical record or prescription record and shall not prescribe or dispense greater than a 3-day supply of a controlled substance to the patient.

A person who willfully and knowingly fails to report the dispensing of a controlled substance as required by this legislation commits a misdemeanor of the first degree, punishable as provided in s. 775.082 or s. 775.083, F.S. Further, the department shall issue a nondisciplinary citation to any prescriber or dispenser who fails to consult the system as required by this subsection for an initial offense. Each subsequent offense is subject to disciplinary action pursuant to s. 456.073, F.S.

If you do not prescribe any controlled substances you are not required to register with or consult E-FORCSE.

You are still authorized to register. You can view your patients' controlled substance dispensing histories and use the "MyRx" report to see if any controlled substances are being dispensed using your DEA number.

Prescribers, dispensers and their designees may register for access at https://florida.pmpaware.net

To review a patient's controlled substance dispensing history prior to prescribing or dispensing a controlled substance in Schedules II-V, as defined in section 893.03, F.S., for patients age 16 and older.

 

  • If the PDMP system is not operational as determined by DOH, or
  • The PDMP cannot be accessed by the prescribing/dispensing practitioner due to a temporary technological or electrical failure or
  • When prescribing or dispensing a nonopioid Schedule V drug or
  • The patient is less than 16 years of age

 

The prescribing/dispensing practitioner must document in the patient’s record the reason the PDMP was not consulted and may prescribe or dispense no more than a 3-day supply of a controlled substance.

Yes

The DOH will issue a non-disciplinary citation for the initial offense.

Any subsequent offense will result in disciplinary action against the prescribing/dispensing practitioner’s license. Disciplinary guidelines are individually established by the appropriate licensing board.

A prescription for a controlled substance listed in Schedule II may not be refilled. However, the dispensing practitioner must consult the PDMP before filling a prescription for a controlled substance listed in Schedule III, Schedule IV, or Schedule V.

The statute does not provide any guidance on how far in advance the PDMP may be consulted. Please refer to your Board's website for further guidance.

The PDMP must be consulted each time a prescription for a controlled substance is written.

Schedules II, III, IV, and V drugs must all be reported.

Yes. Any schedule V controlled substances that are non-opioids and prescriptions dispensed to patients under the age of 16.

 

  1. The telephone number of the person for whom the prescription was written, in addition to the name, address, and date of birth the prescriber currently inputs;
  2. Whether the prescription is an initial prescription or a refill, and the number of refills prescribed;
  3. The name of the individual picking up the controlled substance prescription and the type and issuer of the identification provided; and
  4. The pharmacy's DOH-issued permit number or the dispensing practitioner’s DOH-issued license number

 

Yes. Information that is more than 4 years old.

The Department has published a notice of rule development and will be amending Rule 64K-1.002, FAC . The PDMP will continue to accept submissions in the ASAP 2009 version 4.2 and the new 4.2a standard for one year from the effective date of the rule.

 

  1. The pharmacy permit number or the dispensing health care practitioner's license number.
  2. The name of the individual picking up the controlled substance prescription and type and issuer of the identification provided.

 

A prescribing practitioner can put in refills on a Schedule 3, 4, and 5 substance if the PDMP is consulted before the original prescribing. A prescriber is required to consult the PDMP on new prescriptions. However, a dispenser must consult the PDMP on the new prescription and on each subsequent refill.

Back
Frequently Asked Questions

Pharmacy PSA

IMPORTANT: Updated frequently asked questions for Prescribers and Dispensers

No. There is no limit on writing a prescription for a patient who not experiencing pain. Section 456.44(5), F.S., only applies a 3-day or 7-day supply limit to prescriptions for treatment of acute pain.

All licensed Osteopathic Physicians who are registered with the DEA and authorized to prescribe controlled substances, including Full License holders, Limited License holders, Temporary Certificate holders, Medical Faculty Certificate holders, and Residents, must take this course by January 31, 2019. Taking this course by January 31, 2019, will also fulfill the requirement that the class be taken for the renewal cycle which ends January 31, 2020. The course will need to be taken again during each subsequent renewal. Individuals whose registration or certificate are not renewed, such as Residents, and Medical Facility Certificate holders, will only need to take this course once, by the January 31, 2019, deadline.

The course may be taken live or through distance learning from any one of the four approved providers.

July 1, 2018, except for the provisions related to certificates of exemption for Pain Management Clinics, which are effective January 1, 2019.

Allopathic Physician, Osteopathic Physician, Dentist, Podiatrist, Certified Optometrist, ARNP, and PA.

"Acute pain" is the normal, predicted, physiological, and time-limited response to an adverse chemical, thermal, or mechanical stimulus associated with surgery, trauma, or acute illness. It does not include pain related to cancer, terminal conditions, pain treated with palliative care, or traumatic injuries with an Injury Severity Score of 9 or greater.

A prescription of a Schedule II opioid to alleviate acute paid may not exceed a 3-day supply, codifying the CDC guideline for the treatment of acute pain.

A prescribing practitioner may prescribe up to a 7-day supply if:
(1) the physician determines it is medically necessary; (2) indicates "acute pain exception" on the prescription; AND (3) documents the justification for deviating from the 3-day supply limit in the patient's medical record.

Exceptions to acute pain limits: (1) cancer, (2) a terminal condition, (3) pain treated with palliative care, and (4) a traumatic injury with an Injury Severity Score of 9 or higher. There is NO prescribing limit for these conditions.

A progressive disease or medical or surgical condition that causes significant functional impairment, is not considered by the treating physician to be reversible without the administration of life-sustaining procedures, and will result in death within 1 year after diagnosis if the condition runs its normal course.

The provision of relief for symptoms related to an incurable, progressive illness or injury.

An Injury Severity Score is a method for describing trauma patients with multiple injuries and evaluating emergency care. The score ranges from 1 to 75. See Trauma.org for more information.

When prescribing opioids to a patient with an Injury Severity Score of 9 or higher, the prescriber must also prescribe an emergency opioid antagonist.

The prescriber must indicate "nonacute pain" on the prescription.

This requirement applies to prescriptions for chronic pain, as well as those conditions listed as being excluded from the definition of acute pain.

Yes, each board has disciplinary guidelines that set forth the penalties. Disciplinary guidelines for the Board of Osteopathic Medicine can be found at www.floridasosteopathicmedicine.gov>

All prescribing practitioners registered with the United States Drug Enforcement Agency and authorized to prescribe controlled substances must complete the continuing education course.

2 hours

The course taken by January 31, 2019 will count toward the first renewal cycle. For further questions regarding your renewal period, check with your respective board.

Yes. Advanced Registered Nurse Practitioners and Physician Assistants have a separate 3-hour CE requirement for controlled substances, and are exempted from the new two-hour course.

The course must be offered by a statewide professional association of physicians in this state that is accredited to provide educational activities designated for the American Medical Association Physician’s Recognition Award Category I Credit or the American Osteopathic Category 1-A continuing medical education requirement.

The Florida Medical Association, Florida Osteopathic Medical Association, Florida Academy of Family Physicians, and Florida College of Emergency Physicians.

Yes

https://www.cebroker.com

Go to the course search, under “All Subjects,” click the drop down menu.

Click on “Prescribing Controlled Substances.”

Once the courses are approved, then the Prescribing Controlled Substances tab will lead to registration for the available CE courses.

Drop Down Menu on cebroker.com.

The course may be taken live or through distance learning from any one of the four approved providers.

DOH may not renew the license of a prescriber who fails to complete this continuing education requirement.

A dispensing practitioner is a practitioner authorized by law to prescribe drugs who may dispense such drugs to her or his patients in the regular course of her or his practice in compliance with Section 465.0276, F.S. Dispensing practitioners may include: alleopathic physicians, osteopathic physicians, dentists, optometrists, podiatrists, ARNPs and PAs.

Yes, in compliance with applicable law.

For the treatment of pain other than acute pain, a practitioner must indicate "NONACUTE PAIN" on the prescription. Additionally, for the treatment of pain related to a traumatic injury with an Injury Severity Score of 9 or greater, a dispensing practitioner must concurrently prescribe an emergency opioid antagonist, as defined in s. 381.887(1), F.S.

A registered dispensing practitioner may dispense controlled substances listed in Schedule II or Schedule III which have been approved by the United States Food and Drug Administration for the purpose of treating opiate addictions, including, but not limited to, buprenorphine and buprenorphine combination products, by a practitioner authorized under 21 U.S.C. s. 823, as amended, to the practitioner's own patients for the medication-assisted treatment of opiate addiction.

Dispensing practitioners are required to report to the Prescription Drug Monitoring Program (PDMP) system each time a controlled substance is dispensed to a patient, as soon thereafter as possible, but no later than close of business the day after the prescription is dispensed – unless an extension or exemption is approved by the Department of Health.

A prescribing practitioner can put in refills on a Schedule 3, 4, and 5 substance if the PDMP is consulted before the original prescribing. A prescriber is required to consult the PDMP on new prescriptions. However, a dispenser must consult the PDMP on the new prescription and on each subsequent refill.

Back
Frequently Asked Questions

Pharmacy PSA

IMPORTANT: Updated frequently asked questions for Prescribers and Dispensers

No. There is no limit on writing a prescription for a patient who not experiencing pain. Section 456.44(5), F.S., only applies a 3-day or 7-day supply limit to prescriptions for treatment of acute pain.

No, pharmacists do not prescribe controlled substances, so the specific provisions in this legislation regarding Continuing Education courses for prescribers would not apply. The Board of Pharmacy already requires a mandatory course in CE Broker regarding the validation of prescriptions for controlled substances.

A prescription of a Schedule II opioid to alleviate acute pain may not exceed a 3-day supply, except that that a 7-day supply may be prescribed if certain conditions are met.

A prescribing practitioner may prescribe up to a 7-day supply if:

  • The prescribing practitioner, in his or her professional judgment, believes that more than a 3-day supply of such an opioid is medically necessary to treat the patient's pain as an acute medical condition;
  • The prescribing practitioner indicates "ACUTE PAIN EXCEPTION" on the prescription; and
  • The prescribing practitioner adequately documents in the patient's medical records the acute medical condition and lack of alternative treatment options that justify deviation from the 3-day supply limit.

 

For the treatment of pain other than acute pain, a health care practitioner must indicate "NONACUTE PAIN" on a prescription an opioid drug listed as a Schedule II controlled substance in s. 893.03 or 21 U.S.C. s. 812.

Before dispensing a controlled substance to a person not known to the pharmacist, the pharmacist must require the person purchasing, receiving, or otherwise acquiring the controlled substance to present valid photographic identification or other verification of his or her identity.

Proper identification" means an identification that is issued by a state or the Federal Government containing the person's photograph, printed name, and signature or a document considered acceptable under 8 C.F.R. s. 274a.2(b)(1)(v)(A) and (B).

If the person does not have proper identification, the pharmacist may verify the validity of the prescription and the identity of the patient with the prescriber or his or her authorized agent. Verification of health plan eligibility through a real-time inquiry or adjudication system is also considered to be proper identification.

No

Dispensing practitioners are required to report to the Prescription Drug Monitoring Program (PDMP) system each time a controlled substance is dispensed to a patient, as soon thereafter as possible, but no later than close of business the day after the prescription is dispensed – unless an extension or exemption is approved by the Department of Health.

The following persons must be provided direct access to information in the PDMP system:

  • A prescriber or dispenser or his or her designee; and
  • An employee of the United States Department of Veterans Affairs, the United States Department of Defense, or the Indian Health Service who provides health care services pursuant to such employment and who has the authority to prescribe or dispense controlled substances -- upon verification of employment

 

A prescriber or dispenser or a designee of a prescriber or dispenser must consult the PDMP system to review a patient's controlled substance dispensing history before prescribing or dispensing a controlled substance for a patient age 16 or older.

A prescriber or dispenser or a designee of a prescriber or dispenser does not have to consult the PDMP system when prescribing or dispensing a nonopioid controlled substance listed in Schedule V of s. 893.03 or 21 U.S.C. 812.

The duty to consult the system does not apply when the system:

  • Is determined by the department to be nonoperational; or
  • Cannot be accessed by the prescriber or dispenser or a designee of the prescriber or dispenser because of a temporary technological or electrical failure

 

A prescriber or dispenser or designee of a prescriber or dispenser who does not consult the PDMP system shall document the reason he or she did not consult the system in the patient's medical record or prescription record and shall not prescribe or dispense greater than a 3-day supply of a controlled substance to the patient.

A person who willfully and knowingly fails to report the dispensing of a controlled substance as required by this legislation commits a misdemeanor of the first degree, punishable as provided in s. 775.082 or s. 775.083, F.S. Further, the department shall issue a nondisciplinary citation to any prescriber or dispenser who fails to consult the system as required by this subsection for an initial offense. Each subsequent offense is subject to disciplinary action pursuant to s. 456.073, F.S.

July 1, 2018, except for the provisions related to certificates of exemption for Pain Management Clinics, which are effective January 1, 2019.

January 31, 2019

Yes, each board has disciplinary guidelines that set forth the penalties.

Board specific disciplinary guidelines are found on their board specific sites through flhealthsource.gov.

Dispensing practitioners are required to report to the Prescription Drug Monitoring Program (PDMP) system each time a controlled substance is dispensed to a patient, as soon thereafter as possible, but no later than close of business the day after the prescription is dispensed – unless an extension or exemption is approved by the Department of Health.

If you do not prescribe any controlled substances you are not required to register with or consult E-FORCSE.

You are still authorized to register. You can view your patients' controlled substance dispensing histories and use the "MyRx" report to see if any controlled substances are being dispensed using your DEA number.

Prescribers, dispensers and their designees may register for access at https://florida.pmpaware.net

To review a patient's controlled substance dispensing history prior to prescribing or dispensing a controlled substance in Schedules II-V, as defined in section 893.03, F.S., for patients age 16 and older.

 

  • If the PDMP system is not operational as determined by DOH, or
  • The PDMP cannot be accessed by the prescribing/dispensing practitioner due to a temporary technological or electrical failure or
  • When prescribing or dispensing a nonopioid Schedule V drug or
  • The patient is less than 16 years of age

 

The prescribing/dispensing practitioner must document in the patient’s record the reason the PDMP was not consulted and may prescribe or dispense no more than a 3-day supply of a controlled substance.

Yes

The DOH will issue a non-disciplinary citation for the initial offense.

Any subsequent offense will result in disciplinary action against the prescribing/dispensing practitioner’s license. Disciplinary guidelines are individually established by the appropriate licensing board.

A prescription for a controlled substance listed in Schedule II may not be refilled. However, the dispensing practitioner must consult the PDMP before filling a prescription for a controlled substance listed in Schedule III, Schedule IV, or Schedule V.

The statute does not provide any guidance on how far in advance the PDMP may be consulted. Please refer to your Board's website for further guidance.

The PDMP must be consulted each time a prescription for a controlled substance is written.

Schedules II, III, IV, and V drugs must all be reported.

Yes. Any schedule V controlled substances that are non-opioids and prescriptions dispensed to patients under the age of 16.

 

  1. The telephone number of the person for whom the prescription was written, in addition to the name, address, and date of birth the prescriber currently inputs;
  2. Whether the prescription is an initial prescription or a refill, and the number of refills prescribed;
  3. The name of the individual picking up the controlled substance prescription and the type and issuer of the identification provided; and
  4. The pharmacy's DOH-issued permit number or the dispensing practitioner’s DOH-issued license number

 

Yes. Information that is more than 4 years old.

The Department has published a notice of rule development and will be amending Rule 64K-1.002, FAC . The PDMP will continue to accept submissions in the ASAP 2009 version 4.2 and the new 4.2a standard for one year from the effective date of the rule.

 

  1. The pharmacy permit number or the dispensing health care practitioner's license number.
  2. The name of the individual picking up the controlled substance prescription and type and issuer of the identification provided.

 

A prescribing practitioner can put in refills on a Schedule 3, 4, and 5 substance if the PDMP is consulted before the original prescribing. A prescriber is required to consult the PDMP on new prescriptions. However, a dispenser must consult the PDMP on the new prescription and on each subsequent refill.

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Frequently Asked Questions

Pharmacy PSA

IMPORTANT: Updated frequently asked questions for Prescribers and Dispensers

No. There is no limit on writing a prescription for a patient who not experiencing pain. Section 456.44(5), F.S., only applies a 3-day or 7-day supply limit to prescriptions for treatment of acute pain.

July 1, 2018, except for the provisions related to certificates of exemption for Pain Management Clinics, which are effective January 1, 2019.

January 31, 2019

Allopathic Physician, Osteopathic Physician, Dentist, Podiatrist, Certified Optometrist, ARNP, and PA.

"Acute pain" is the normal, predicted, physiological, and time-limited response to an adverse chemical, thermal, or mechanical stimulus associated with surgery, trauma, or acute illness. It does not include pain related to cancer, terminal conditions, pain treated with palliative care, or traumatic injuries with an Injury Severity Score of 9 or greater.

A prescription of a Schedule II opioid to alleviate acute paid may not exceed a 3-day supply, codifying the CDC guideline for the treatment of acute pain.

A prescribing practitioner may prescribe up to a 7-day supply if:
(1) the physician determines it is medically necessary; (2) indicates "acute pain exception" on the prescription; AND (3) documents the justification for deviating from the 3-day supply limit in the patient's medical record.

Exceptions to acute pain limits: (1) cancer, (2) a terminal condition, (3) pain treated with palliative care, and (4) a traumatic injury with an Injury Severity Score of 9 or higher. There is NO prescribing limit for these conditions.

A progressive disease or medical or surgical condition that causes significant functional impairment, is not considered by the treating physician to be reversible without the administration of life-sustaining procedures, and will result in death within 1 year after diagnosis if the condition runs its normal course.

The provision of relief for symptoms related to an incurable, progressive illness or injury.

An Injury Severity Score is a method for describing trauma patients with multiple injuries and evaluating emergency care. The score ranges from 1 to 75. See Trauma.org for more information.

When prescribing opioids to a patient with an Injury Severity Score of 9 or higher, the prescriber must also prescribe an emergency opioid antagonist.

The prescriber must indicate "nonacute pain" on the prescription.

This requirement applies to prescriptions for chronic pain, as well as those conditions listed as being excluded from the definition of acute pain.

Yes, each board has disciplinary guidelines that set forth the penalties.

Board specific disciplinary guidelines are found on their board specific sites through flhealthsource.gov.

All prescribing practitioners registered with the United States Drug Enforcement Agency and authorized to prescribe controlled substances must complete the continuing education course.

2 hours

January 31, 2019 AND at each subsequent licensure renewal.

The course taken by January 31, 2019 will count toward the first renewal cycle. For further questions regarding your renewal period, check with your respective board.

Yes. Advanced Registered Nurse Practitioners and Physician Assistants have a separate 3-hour CE requirement for controlled substances, and are exempted from the new two-hour course.

The course must be offered by a statewide professional association of physicians in this state that is accredited to provide educational activities designated for the American Medical Association Physician’s Recognition Award Category I Credit or the American Osteopathic Category 1-A continuing medical education requirement.

The Florida Medical Association, Florida Osteopathic Medical Association, Florida Academy of Family Physicians, and Florida College of Emergency Physicians.

Yes

https://www.cebroker.com

Go to the course search, under “All Subjects,” click the drop down menu.

Click on “Prescribing Controlled Substances.”

Once the courses are approved, then the Prescribing Controlled Substances tab will lead to registration for the available CE courses.

Drop Down Menu on cebroker.com.

The course may be taken live or through distance learning from any one of the four approved providers.

DOH may not renew the license of a prescriber who fails to complete this continuing education requirement.

A dispensing practitioner is a practitioner authorized by law to prescribe drugs who may dispense such drugs to her or his patients in the regular course of her or his practice in compliance with Section 465.0276, F.S. Dispensing practitioners may include: alleopathic physicians, osteopathic physicians, dentists, optometrists, podiatrists, ARNPs and PAs.

Yes, in compliance with applicable law.

For the treatment of pain other than acute pain, a practitioner must indicate "NONACUTE PAIN" on the prescription. Additionally, for the treatment of pain related to a traumatic injury with an Injury Severity Score of 9 or greater, a dispensing practitioner must concurrently prescribe an emergency opioid antagonist, as defined in s. 381.887(1), F.S.

A registered dispensing practitioner may dispense a 3-day supply of controlled substances for the treatment of acute pain. A 7-day supply may be dispensed if certain criteria in Section 456.44(5)(a), F.S. are met. Additionally, for a controlled substance listed in Schedule III, the amount dispensed may not exceed a 14-day supply.

The law regarding the limitations on controlled substances did not change in this area. A dispensing practitioner may not allow for the dispensing of a controlled substance listed in Schedule II or Schedule III more than 14 days after the performance of a surgical procedure.

A registered dispensing practitioner may dispense controlled substances listed in Schedule II or Schedule III which have been approved by the United States Food and Drug Administration for the purpose of treating opiate addictions, including, but not limited to, buprenorphine and buprenorphine combination products, by a practitioner authorized under 21 U.S.C. s. 823, as amended, to the practitioner's own patients for the medication-assisted treatment of opiate addiction.

Before dispensing a controlled substance to a person not known to the practitioner, he or she must require the person purchasing, receiving, or otherwise acquiring the controlled substance to present valid photographic identification or other verification of his or her identity.

Proper identification" means an identification that is issued by a state or the Federal Government containing the person's photograph, printed name, and signature or a document considered acceptable under 8 C.F.R. s. 274a.2(b)(1)(v)(A) and (B).

If the person does not have proper identification, the pharmacist may verify the validity of the prescription and the identity of the patient with the prescriber or his or her authorized agent. Verification of health plan eligibility through a real-time inquiry or adjudication system is also considered to be proper identification.

No

Dispensing practitioners are required to report to the Prescription Drug Monitoring Program (PDMP) system each time a controlled substance is dispensed to a patient, as soon thereafter as possible, but no later than close of business the day after the prescription is dispensed – unless an extension or exemption is approved by the Department of Health.

A prescriber or dispenser or a designee of a prescriber or dispenser must consult the PDMP system to review a patient's controlled substance dispensing history before prescribing or dispensing a controlled substance for a patient age 16 or older.

A prescriber or dispenser or a designee of a prescriber or dispenser does not have to consult the PDMP system when prescribing or dispensing a nonopioid controlled substance listed in Schedule V of s. 893.03 or 21 U.S.C. 812.

The duty to consult the system does not apply when the system:

  • Is determined by the department to be nonoperational; or
  • Cannot be accessed by the prescriber or dispenser or a designee of the prescriber or dispenser because of a temporary technological or electrical failure

 

A prescriber or dispenser or designee of a prescriber or dispenser who does not consult the PDMP system shall document the reason he or she did not consult the system in the patient's medical record or prescription record and shall not prescribe or dispense greater than a 3-day supply of a controlled substance to the patient.

A person who willfully and knowingly fails to report the dispensing of a controlled substance as required by this legislation commits a misdemeanor of the first degree, punishable as provided in s. 775.082 or s. 775.083, F.S. Further, the department shall issue a nondisciplinary citation to any prescriber or dispenser who fails to consult the system as required by this subsection for an initial offense. Each subsequent offense is subject to disciplinary action pursuant to s. 456.073, F.S.

If you do not prescribe any controlled substances you are not required to register with or consult E-FORCSE.

You are still authorized to register. You can view your patients' controlled substance dispensing histories and use the "MyRx" report to see if any controlled substances are being dispensed using your DEA number.

Prescribers, dispensers and their designees may register for access at https://florida.pmpaware.net

To review a patient's controlled substance dispensing history prior to prescribing or dispensing a controlled substance in Schedules II-V, as defined in section 893.03, F.S., for patients age 16 and older.

 

  • If the PDMP system is not operational as determined by DOH, or
  • The PDMP cannot be accessed by the prescribing/dispensing practitioner due to a temporary technological or electrical failure or
  • When prescribing or dispensing a nonopioid Schedule V drug or
  • The patient is less than 16 years of age

 

The prescribing/dispensing practitioner must document in the patient’s record the reason the PDMP was not consulted and may prescribe or dispense no more than a 3-day supply of a controlled substance.

Yes

The DOH will issue a non-disciplinary citation for the initial offense.

Any subsequent offense will result in disciplinary action against the prescribing/dispensing practitioner’s license. Disciplinary guidelines are individually established by the appropriate licensing board.

A prescription for a controlled substance listed in Schedule II may not be refilled. However, the dispensing practitioner must consult the PDMP before filling a prescription for a controlled substance listed in Schedule III, Schedule IV, or Schedule V.

The statute does not provide any guidance on how far in advance the PDMP may be consulted. Please refer to your Board's website for further guidance.

The PDMP must be consulted each time a prescription for a controlled substance is written.

Schedules II, III, IV, and V drugs must all be reported.

Yes. Any schedule V controlled substances that are non-opioids and prescriptions dispensed to patients under the age of 16.

 

  1. The telephone number of the person for whom the prescription was written, in addition to the name, address, and date of birth the prescriber currently inputs;
  2. Whether the prescription is an initial prescription or a refill, and the number of refills prescribed;
  3. The name of the individual picking up the controlled substance prescription and the type and issuer of the identification provided; and
  4. The pharmacy's DOH-issued permit number or the dispensing practitioner’s DOH-issued license number

 

Yes. Information that is more than 4 years old.

The Department has published a notice of rule development and will be amending Rule 64K-1.002, FAC . The PDMP will continue to accept submissions in the ASAP 2009 version 4.2 and the new 4.2a standard for one year from the effective date of the rule.

 

  1. The pharmacy permit number or the dispensing health care practitioner's license number.
  2. The name of the individual picking up the controlled substance prescription and type and issuer of the identification provided.

 

A prescribing practitioner can put in refills on a Schedule 3, 4, and 5 substance if the PDMP is consulted before the original prescribing. A prescriber is required to consult the PDMP on new prescriptions. However, a dispenser must consult the PDMP on the new prescription and on each subsequent refill.