Proposed Rule for Dispensing and Prescribing Controlled Drugs for Detoxification Treatment

MEMORANDUM
Memorandum
HYPOTHETICAL SCENARIO- DRUG ENFORCEMENT
ADMINISTRATION
0 | P a g e

MEMORANDUM
To
Mickey Disney,
The Supervisor
Date: April 10, 2019
Sub:a Proposed rule allowing qualified practitioners to dispense and prescribe to narcotic
dependent persons certain controlled drugs that are approved by the FDA for detoxification
treatment, along withwhetherDEA can opt for negotiated rulemaking
Dear Mr. Disney
This is to inform you that, I have been assigned to draft a proposed rule for allowing qualified
practitioners to dispense and prescribe to narcotic dependent persons certain controlled drugs that
are approved by the FDA for detoxification treatment as mentioned under (Federal Register
Notices > Rules - 2005 > Authority for Practitioners To Dispense or Prescribe Approved
Narcotic Controlled Substances for Maintenance or Detoxification Treatment).
The proposed rule is for clarification for the practice of using “Do Not Fill Until ___” method
which is used for writing prescriptions required for prescribing the Schedule II controlled
substance. As the code of federal regulations under section 1306.05 states the manner for issuing
the prescriptions for controlled substances(Electronic Code of Federal Regulations- Title 21 →
Chapter II → Part 1306 →§1306.05 Manner of issuance of prescriptions), however, for
prescribing opioid under Schedule II controlled substance, the quantity of medications must be
divided in half, so, for each prescription the issuing date will be same, but in another it will
above- mentioned method. The patient with stable pain generally comes in a clinic in 2 months’
time, but insurance companies pay for the months' supply, and the practitioner does not want to
1 | P a g e