Controlled Substance Prescribing Policy

    Understanding our policies for prescribing controlled substances, DEA compliance, patient monitoring requirements, and when controlled medications may not be appropriate.

    This policy applies to all controlled substance prescribing provided by TruCare Health, including both in-person office visits and telemedicine encounters.

    DEA Compliance & Regulatory Framework

    TruCare Health operates in full compliance with the Drug Enforcement Administration (DEA) regulations, state medical board requirements, and the Controlled Substances Act (CSA). Our prescribers maintain active DEA registrations and follow all applicable federal and state laws.

    Federal Regulations

    • Compliance with DEA regulations (21 CFR Part 1300)
    • Controlled Substances Act (21 U.S.C. § 801 et seq.)
    • SUPPORT for Patients and Communities Act
    • Ryan Haight Act and any current DEA telemedicine prescribing regulations and temporary extensions
    • Prescription Drug Monitoring Program (PDMP) requirements

    State Requirements

    • California Medical Board prescribing guidelines
    • Texas Medical Board controlled substance rules
    • State-specific PDMP reporting and queries
    • Mandatory continuing education on prescribing practices
    • State-mandated informed consent requirements

    Provider DEA Registrations

    All TruCare Health prescribers maintain current DEA registrations in the states where they practice:

    • • Dr. Uzma Ahmed - DEA Registration Active (California)
    • • Breanna Caro, PA-C - DEA Registration Active (California)
    • • Victoria Randazzo, NP - DEA Registration Active (California)

    Understanding DEA Schedule Classifications

    Schedule II - Highest Restriction

    High potential for abuse, accepted medical use, severe psychological or physical dependence

    Examples: Oxycodone, Hydrocodone, Morphine, Fentanyl, Amphetamines, Methylphenidate

    Prescribing Rules: No refills permitted, written or electronic prescriptions only, 30-day supply limit in most cases

    Schedule III

    Moderate to low potential for physical and psychological dependence

    Examples: Testosterone, Ketamine, Anabolic steroids, Codeine combinations

    Prescribing Rules: Up to 5 refills within 6 months, can be called in by provider

    Schedule IV

    Low potential for abuse and limited dependence

    Examples: Benzodiazepines (Xanax, Valium, Ativan), Tramadol, Ambien, Phentermine

    Prescribing Rules: Up to 5 refills within 6 months

    Schedule V

    Lower potential for abuse than Schedule IV

    Examples: Cough preparations with codeine, Pregabalin (Lyrica)

    Prescribing Rules: Most lenient restrictions, some may be available without prescription

    Prescribing Limitations & Requirements

    Telemedicine Prescribing Requirements

    The Ryan Haight Act and state regulations impose specific requirements for prescribing controlled substances via telemedicine:

    • Schedule II Medications: May be subject to in-person evaluation requirements depending on current DEA regulations and applicable exceptions
    • Opioids: TruCare Health does not prescribe opioid medications (Schedule II narcotics) via telemedicine except in extraordinary circumstances and with documented medical necessity
    • Schedule III-V: May be prescribed via telemedicine after appropriate evaluation and establishment of valid provider-patient relationship
    • Testosterone (Schedule III): Prescribable via telemedicine with appropriate labs, evaluation, and medical necessity

    Benzodiazepine Prescribing

    • Benzodiazepines are generally not prescribed as first-line treatment for anxiety or insomnia
    • Long-term benzodiazepine therapy may require psychiatric evaluation or co-management
    • Concurrent opioid and benzodiazepine prescribing is generally prohibited unless medically necessary and documented
    • Patients receiving benzodiazepines may be subject to periodic urine drug screening and PDMP review

    Quantity and Duration Limits

    • Initial prescriptions typically limited to 30-day supply for Schedule II-IV medications
    • Refills require follow-up evaluation and assessment of ongoing medical necessity
    • Early refill requests require documentation of lost/stolen medication or travel circumstances
    • Maximum morphine milligram equivalent (MME) limits apply to opioid prescriptions

    Mandatory Documentation

    • Detailed medical history and physical examination findings
    • Documented diagnosis justifying controlled substance use
    • Treatment plan with defined goals and measurable outcomes
    • Informed consent documenting risks, benefits, and alternatives
    • PDMP query results reviewed before prescribing

    Patient Monitoring Requirements

    Required Monitoring for Controlled Substance Patients

    Patients receiving controlled substances must comply with the following monitoring requirements:

    Regular Follow-Up Visits

    • Schedule II: Monthly evaluation required
    • Schedule III-IV: Quarterly evaluation minimum
    • Assessment of treatment effectiveness
    • Evaluation of adverse effects or complications
    • Review of adherence to treatment plan

    Laboratory Testing

    • Urine drug screening (random or scheduled)
    • Baseline and periodic liver/kidney function tests
    • Hormone levels (for testosterone and related therapies)
    • Complete blood count (CBC) when indicated
    • Additional testing based on medication type

    Prescription Drug Monitoring Program (PDMP)

    TruCare Health queries state PDMPs before prescribing and at regular intervals:

    • PDMP check required before initial controlled substance prescription
    • PDMP review prior to initiation and periodically thereafter in accordance with state law and provider judgment
    • Identification of potential drug interactions or "doctor shopping"
    • Documentation of PDMP results in patient medical record
    • Immediate review if concerning prescribing patterns identified

    Patient Treatment Agreement

    All patients receiving controlled substances must sign a treatment agreement that includes:

    • Commitment to obtain controlled substances from only one provider
    • Agreement to use only one pharmacy for controlled substance prescriptions
    • Consent to random urine drug screens
    • Understanding of safe storage and disposal requirements
    • Acknowledgment that early refills will not be provided
    • Agreement to attend all scheduled follow-up appointments

    When Controlled Substances Will NOT Be Prescribed

    TruCare Health reserves the right to decline controlled substance prescriptions in the following circumstances:

    Absence of Valid Medical Indication

    Controlled substances will not be prescribed without a documented medical condition that justifies their use. Cosmetic purposes, performance enhancement (non-medical), or patient request alone are insufficient justification.

    Active Substance Use Disorder

    Patients with untreated substance use disorder or active addiction will be referred to appropriate addiction treatment services. Controlled substances may be withheld until the patient is engaged in treatment and medically stable.

    Evidence of Diversion or Misuse

    Prescriptions will be denied if there is evidence of medication diversion (selling, sharing, trading), misuse (taking medications not as prescribed), or "doctor shopping" (obtaining controlled substances from multiple providers without disclosure).

    Abnormal Urine Drug Screen Results

    Unexpected drug screen results (presence of non-prescribed substances, absence of prescribed medication) may result in treatment termination or prescription refusal until explanation is provided and treatment plan is reassessed.

    Non-Compliance with Treatment Plan

    Patients who miss scheduled appointments, fail to complete required monitoring, refuse drug screens, or do not follow treatment recommendations may have prescriptions discontinued.

    Concurrent Prescriptions from Other Providers

    PDMP review showing controlled substance prescriptions from other providers without coordination will result in prescription refusal. Patients must disclose all controlled substance prescriptions and coordinate care among treating providers.

    Threatening or Abusive Behavior

    Any threatening, abusive, or violent behavior toward staff will result in immediate dismissal from the practice and law enforcement notification if warranted.

    Criminal Activity Related to Controlled Substances

    Patients involved in criminal activity related to controlled substances (forgery of prescriptions, theft, drug trafficking) will be dismissed from the practice and reported to appropriate authorities.

    Inadequate Initial Evaluation

    For telemedicine visits, if the provider determines that an in-person physical examination is necessary before prescribing controlled substances, patients will be required to schedule an in-person visit or seek care locally.

    High-Risk Medication Combinations

    Controlled substances will not be prescribed in combination with other high-risk medications unless medically necessary and with enhanced monitoring protocols. Examples include: Opioids + Benzodiazepines, Multiple Benzodiazepines, Stimulants + Benzodiazepines, Stimulants + Opioids.

    Lost or Stolen Medication (Repeated Claims)

    Replacement of lost or stolen controlled substances is not guaranteed and is at the sole discretion of the prescribing provider. Repeated claims will result in prescription refusal and possible dismissal from the practice.

    Patient Located Outside Licensed States

    Controlled substances cannot be prescribed to patients physically located in states where our providers do not hold active medical licenses or DEA registrations.

    ADHD / Stimulant Policy

    TruCare Health does not initiate stimulant therapy for ADHD through telemedicine without appropriate diagnostic evaluation and supporting documentation. Providers may require prior medical records, psychological testing, or in-person evaluation before prescribing stimulant medications.

    Patient Rights & Responsibilities

    Your Rights

    • Receive clear explanation of treatment plan and alternatives
    • Ask questions and receive honest answers about your medications
    • Refuse controlled substance treatment and discuss alternatives
    • Request a second opinion or transfer to another provider
    • Confidential treatment of your medical information per HIPAA

    Your Responsibilities

    • Take medications only as prescribed
    • Store medications securely to prevent theft or misuse by others
    • Dispose of unused medications properly at DEA-authorized take-back locations
    • Inform your provider of all medications, including over-the-counter and supplements
    • Report side effects or concerns immediately
    • Never share, sell, or give your medications to others
    • Comply with all monitoring requirements including drug screens and follow-up visits

    Safe Medication Disposal

    Proper disposal of controlled substances prevents environmental contamination and accidental ingestion:

    • DEA Take-Back Programs: Find locations at DEA's website
    • Authorized Collection Sites: Many pharmacies, hospitals, and police stations accept unused medications
    • Never flush or throw in trash: Improper disposal can contaminate water supplies and soil
    • Contact our office at (714) 532-6713 for disposal guidance