Hydrocodone combination products to become Schedule II drugs

On October 6, new Drug Enforcement Administration (DEA) requirements will be in place for all hydrocodone-containing products (HCPs). See DEA’s Final Rule for more details. Specifically, all HCPs will be Schedule II drugs, whereas at the present time, some are Schedule II, while others are Schedule III drugs. Hydrocodone is used at times in canine medicine for its ability to help control coughing in dogs and for pain control, so the scheduling change could be particularly of interest to small animal veterinarians.

So what does this new scheduling change mean for veterinarians? First, veterinarians who want to treat patients with HCPs on or after October 6 will need to make certain they are registered with the DEA to handle Schedule II substances. Registrants will be required to follow all other Schedule II requirements (see DEA rules or Practitioner’s Manual):

  • Use Form 222 to order HCPs and secure storage of Form 222.
  • If dispensing from the clinic: check state rules which might limit the dispensed amount to a 30-day supply at one time.
  • If prescribing: provide a written prescription (not phone or fax, unless it’s for a short-term emergency, followed by sending a prescription in written form within 7 days) with zero refills. The prescription, or set of prescriptions can provide up to a 90-day supply maximum, for the client to have dispensed at a pharmacy of their choice.
  • Maintain detailed records in a physical file for Schedule II, separate from Schedule III-V records.
  • Keep accurate and detailed inventory records for HCPs and other Schedule II substances.

Note that for hydrocodone Schedule III prescriptions that are provided to clients before October 6, refills are allowed so long as they are dispensed before April 8, 2015. Thereafter, refills will not be allowed because all hydrocodone products will be Schedule II (and therefore ineligible for prescription refills).

Be sure to check state rules which might be more stringent. For additional details, also see the AVMA’s Veterinary Compliance with the DEA and the Controlled Substance Act.

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