Who’s on first… what is on second…

I got this the other day from the DEA via the KY BOP

PRESCRIPTION FOR A SCHEDULE II

If a pharmacist receives a prescription for a Schedule II controlled substance and a third party provider will only pay for a partial quantity of the amount prescribed there is only one option: if your computer software allows the same prescription number to be assigned on the same day then the prescription can be filled for the total quantity. Two prescription numbers cannot be issued to dispense the total quantity. According to DEA the only time you can partially fill a Schedule II controlled substance is if the pharmacy is out of the controlled substance and more will be received within 72 hours and it is dispensed to the patient within the 72 hours from the original date dispensed.

I have read this statement several times

What computer system will allow you to fill a Rx twice using the SAME NUMBER… isn’t this technically called a REFILL? What computer system will allow you to REFILL a C-II?

What PBM will allow you to bill the same drug on the same day and not give you a REJECT for DUP CLAIM?

Why does Fed DEA law allow LTCP’s to refill C-II’s until whatever date limitation that the state has on all Rxs or C-II’s in particular… and retail/community doesn’t have the same options?

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