On January 1, 2019, a new California law takes effect that requires all security prescription forms to have a uniquely serialized number. This new law also requires California physicians who prescribe controlled substances to use updated controlled substance prescription forms effective January 1, 2019.

Although technically, this requirement goes into effect January 1, the California Department of Justice (DOJ) only very recently issued any guidance as to the manner in which the serialized number is going to go on the prescriptions forms.

Physicians were finally notified this week that the updated forms were available for purchase from some of the currently approved vendors, with less than two weeks to go before the compliance date. The California Medical Association (CMA) is very concerned that this does not provide enough time for physicians to re-order forms and integrate the use of the new forms for use beginning January 1, 2019, and could be a serious barrier to patients who must access necessary medications in a timely manner.

CMA has expressed concern to DOJ that this guidance was not given in timely enough manner for it to be implemented by physician prescribers and will result in a serious disruption of patient care. CMA is urging DOJ to work with the Medical Board of California and the California Board of Pharmacy to allow for a transitional period for pharmacies to accept prescription forms that are not fully compliant with the new requirement to ensure continuity of care for California patients.

Reordering security prescription forms presents a great expense for many physician practices and CMA has urged DOJ to work with CMA and other stakeholders to ensure compliance with this new requirement in a way that does not adversely affect patient care.

Physicians should be prepared to make sure their security prescription vendors are ready to comply with the new requirements. CMA's security prescription partner, RxSecurity, is now taking orders for the new uniquely serialized prescription forms. 

CMA will provide additional information as it becomes available.

For more details, see CMA’s letter to DOJ on this issue.

For updated updated information on DOJ's approved vendors, click here.