How to use this cheat sheet: Print it, review it the night before your exam, and use it during your final week to quickly verify your knowledge of high-yield facts. This is NOT a substitute for full study — it is a revision tool.
💊 Controlled Substance Schedules
CI: No medical use. Cannot prescribe. (heroin, LSD, MDMA, peyote, marijuana-federal)
CII: High abuse. No refills. Written/electronic only. Emergency = 72hr supply. (oxycodone, fentanyl, morphine, methylphenidate, amphetamine)
CIII-CV: 5 refills in 6 months. One-time transfer (unless shared database). CIII = buprenorphine, ketamine, testosterone. CIV = benzodiazepines, zolpidem, tramadol. CV = pregabalin, codeine cough preps
📋 DEA Forms
DEA 222: Order CII drugs (triplicate or CSOS electronic). POA can sign. Max 10 items.
DEA 41: Biennial inventory. CII = exact count. CIII-V = estimated (exact if opened).
DEA 106: Report theft/significant loss. File immediately + notify DEA Diversion office.
DEA 224/224a: New registration / renewal. Valid 3 years. Separate per location.
Records retention: All CS records kept minimum 2 years.
🔒 HIPAA Quick Facts
TPO: Treatment, Payment, Healthcare Operations — no patient authorization needed.
Minimum necessary: Applies to all disclosures EXCEPT treatment communications.
Breach ≥500: Notify individuals + HHS + media within 60 days.
Breach <500: Notify individuals within 60 days. Annual log to HHS.
42 CFR Part 2: Substance abuse records — stricter than HIPAA. Requires specific written consent even for treatment.
Patient rights: Access PHI (30 days), request amendment, accounting of disclosures (6 years), request restrictions, NPP, confidential communications.
💨 CMEA (Pseudoephedrine)
Daily limit: 3.6 grams per purchaser
Monthly limit: 9 grams (mail-order: 7.5 grams)
Behind counter. Photo ID + logbook required. Logbook retained 2 years. 18+ to purchase.
👶 PPPA (Child-Resistant Packaging)
Default: ALL legend drugs and CS in child-resistant containers.
Exceptions: Sublingual nitroglycerin, oral contraceptives, effervescent aspirin/acetaminophen, hormone replacement in manufacturer unit-dose, inhalation aerosols, potassium supplements in unit-dose.
Patient/prescriber may request: Non-child-resistant container (blanket waiver = all future Rxs; per-Rx waiver). Prescriber can request for specific Rx.
⚖️ OBRA-90
Applies to: Medicaid prescriptions (most states extend to all Rxs).
Requires: Offer to counsel on all new prescriptions. Prospective drug utilization review (DUR). Maintain patient medication profiles.
💻 EPCS (E-Prescribing CS)
Federal: E-prescribing of ALL CS (including CII) is permitted since 2010.
Requires: Two-factor authentication for prescriber. DEA-certified application.
Many states: NOW REQUIRE EPCS for CS (check your state).
🏥 Ryan Haight Act
Rule: At least one in-person medical evaluation required before prescribing CS via internet/telemedicine.
Exception: DEA-registered telemedicine practitioners in qualifying practice settings (hospital, VA, IHS, public health emergency).
Applies to: Internet pharmacies dispensing controlled substances — must display DEA internet pharmacy registration.
📦 DSCSA (Drug Supply Chain Security Act)
Transaction documentation: TI (Transaction Information), TH (Transaction History), TS (Transaction Statement) — required for each sale between trading partners.
Suspect product: Quarantine, investigate, notify FDA if determined illegitimate.
Verification: Pharmacies must verify product identifiers (NDC, serial number, lot, expiration) before dispensing if suspect.
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