Hydrocodone Reclassification: What physicians need to know

4539848_GRecently, the Drug Enforcement Administration (DEA) issued a final rule rescheduling hydrocodone combination products (HCPs) into Controlled Substance Schedule II, effective October 6, 2014.


Rescheduling issues directly related to Arkansas:

  1. Under Arkansas law, physician assistants and advance practice registered nurses are not authorized to write prescriptions for Schedule II drugs.
  2. Some pharmacies, particularly those large chain stores are making a policy decision not to recognize refills beginning on October 6th.  In those instances, new prescriptions will be needed.

General Information

(from the AMA’s “Advocacy Update”)
The DEA clarified key points impacting implementation that are of interest to health care providers and patients:
Impact of State Law:
  • State law, if more stringent, will govern how HCPs are handled with respect to refills. Several states have published notices that they intend to treat HCP refills for prescriptions written prior to October 6, 2014 like the federal rule. However, most states have not provided clarity. Thus, prescribers should be prepared to provide new hard copy or electronic prescriptions for patients beginning on October 6, 2014 rather than have patients use what would have been existing refills.
Impact on Prescribers Starting on October 6, 2014:
Impact on Patients Starting on October 6, 2014:
How Prescribers Should Prepare for October 6, 2014:

*Except for limited quantities in emergency situations. In emergency situations, a pharmacist may dispense a Schedule II controlled substance upon oral authorization of a prescribing individual practitioner, provided that the quantity is limited to the amount needed to treat the patient during the emergency period, the prescription is immediately reduced to writing and delivered to the pharmacy within seven days, and the pharmacist makes a reasonable effort to determine that the oral authorization came from a registered individual practitioner. If the hard copy prescription is not received by the pharmacy in seven days, the pharmacist should notify the DEA.