13.1 Transferring Prescriptions

Why a transfer is not a new prescription

Quick Answer: Move remaining authorized refills of a noncontrolled prescription under CGS § 20-616(e). Move CIII–V refill information under 21 CFR 1306.25 and CGS § 21a-249(l)(1)(A) — one time between pharmacies, unless they electronically share a real-time, online database. Move an unfilled electronically transmitted CII–V prescription one time, on the patient’s request, remaining in electronic form, pharmacist to pharmacist (21 CFR 1306.08(e)–(i); CGS § 21a-249(l)(1)(B)). A filled Schedule II prescription does not transfer. Two licensed pharmacists complete a controlled-substance transfer. Void the original, record remaining refills, dates, and pharmacy identifiers.

NABP Competency 3.2 tests whether the leftover therapy still lives at Pharmacy A or has legally moved to Pharmacy B. Candidates fail this item by treating every transfer like a lisinopril refill, by “transferring” a filled oxycodone, or by letting a technician take a clonazepam transfer while the pharmacist bags another order.

A transfer is a movement of existing prescription information. It is not a new authorization from the prescriber. The receiving pharmacy inherits only what the original still had — remaining fills, remaining time on the six-month CIII–IV clock, and the original SIG. If Pharmacy A already used the last refill, there is nothing left to send.

Noncontrolled prescriptions — remaining refills, as authorized

CGS § 20-616(e) is the Chapter 400j transfer rule, and it is limited to a prescription that is not for a controlled drug. Three conditions must all be true:

1. The practitioner authorized the original prescription to be refilled under § 20-616(b).
2. The pharmacist transferring the prescription cancels the original in that pharmacy’s records and notes the name of the receiving pharmacy and the date of the transfer. Cancellation is not required when the two pharmacies electronically access the same prescription records and use the same computer or other electronic prescription transfer system.
3. The pharmacist receiving the prescription records, in addition to other required information: (A) that the prescription has been transferred and the names of the transferring pharmacy and pharmacist; (B) the date of issuance and the original prescription number; (C) the date the original was first dispensed; (D) the number of refills authorized and the complete refill record as of the transfer date; and (E) the number of valid refills remaining.

That last clause is the exam’s math problem. A Hartford prescription written for five refills, already filled twice, arrives in New Haven as three remaining refills, not as a new five-refill original. PRN or ad lib on a noncontrolled blank still transfers only as the original authorized; Chapter 9 already warned that those words are not a Connecticut one-year statute.

The shared-system exception is how a chain with a real-time common database moves a noncontrolled profile from a Stamford store to a Bridgeport store without a VOID rubber stamp. Independent pharmacies that do not share that database still cancel.

CIII–V refill transfers — federal 21 CFR 1306.25, then Connecticut

21 CFR 1306.25(a) is the refill-transfer rule for Schedule III, IV, or V: original prescription information may be transferred on a one-time basis only. However, pharmacies that electronically share a real-time, online database may transfer up to the maximum refills permitted by law and the prescriber’s authorization. Subsection (e) adds that the procedure is allowed only if state law also allows it.

CGS § 21a-249(l)(1)(A) is Connecticut’s yes: any pharmacy may transfer a CIII, CIV, or CV prescription to any other pharmacy in accordance with the federal CSA and its regulations. Connecticut does not publish a tighter one-transfer-per-lifetime rule than 1306.25. The federal one-time / shared-database split therefore controls, sitting on top of CGS § 21a-249(h)’s six-month / five-refill cap for III and IV (Chapter 9).

21 CFR 1306.25(b) is the documentation checklist the MPJE grades:

• The transfer must be communicated directly between two licensed pharmacists.
• The transferring pharmacist writes “VOID” on the face of a paper prescription (or, for an electronic prescription, adds information that it has been transferred); records on the reverse (or in the electronic record) the name, address, and DEA number of the receiving pharmacy and the name of the receiving pharmacist; and records the date and the name of the transferring pharmacist.
• The receiving pharmacist writes “transfer” on a paper/oral reduced-to-writing prescription and captures original issuance date, original refill count, original dispensing date, remaining refills and prior refill dates/locations, transferring pharmacy identifiers and Rx number, transferring pharmacist’s name, and — if different — the pharmacy that originally filled the prescription.

Federal 1306.25(c) keeps original and transferred prescriptions two years from the last refill. Connecticut CS records are three years (CGS § 21a-249(n); Chapter 15). More-restrictive Connecticut retention wins.

Unfilled electronic CII–V — the 2023 DEA overlay Connecticut already pointed to

A filled Schedule II prescription has no refills (21 U.S.C. § 829(a); 21 CFR 1306.12). There is nothing 1306.25 can move. An unfilled paper CII is also not a 1306.25 refill transfer. The modern path is unfilled EPCS.

CGS § 21a-249(l)(1)(B) (July 2020 special session) lets a pharmacy transfer an unfilled prescription for CII, III, IV, or V that was electronically transmitted, in accordance with the CSA and DEA regulations. The pharmacy may transfer that unfilled electronic prescription by telephone or other electronic transmission if:

• The transfer is consistent with the federal CSA, its regulations, and DEA policy;
• The first pharmacy prevents the prescription from being filled anywhere else and records the receiving pharmacy’s name, telephone number, and address plus the receiving pharmacist’s name and license number; and
• The receiving pharmacy records the § 21a-249(a) elements, that the prescription was transferred, the first pharmacy’s name, the issue date, the transfer date, and any refills if the drug is III, IV, or V.

Subsection (l)(2) still says the first pharmacy may send a facsimile of the prescription information if it is transferring by telephone. Read that sentence with (l)(1)(B)(i). Consistency with current DEA regulations is a statutory condition, not an optional courtesy.

21 CFR 1306.08(e)–(i), added by DEA’s July 27, 2023 final rule and effective August 28, 2023, is that current federal text:

• Transfer for initial dispensing of an electronic CII–V prescription is allowed between retail pharmacies, upon request from the patient, on a one-time basis only.
• If the unfilled prescription is CIII–V and includes authorized refills, those refills transfer with the original.
• The prescription must remain in its electronic form. An intermediary may not convert it to facsimile or paper for transmission.
• Contents required by Part 1306 must not be altered during the transfer.
• The transfer must be communicated directly between two licensed pharmacists.
• Both pharmacists annotate the electronic record (transferred / transfer, pharmacy name-address-DEA, pharmacist names, date).
• The transfer is allowed only if state law allows it — Connecticut does, in § 21a-249(l)(1)(B).
• Electronic transfer records: federal two years from the transfer date; Connecticut CS files still three years.

Exam reconciliation: Connecticut’s 2020 statute still mentions telephone and a follow-on fax. After August 28, 2023, DEA requires the EPCS itself to stay electronic. A pharmacist-to-pharmacist conversation can still accompany that electronic forward; converting the unfilled CII into a phoned-in oral order, or treating a fax as the transferred prescription, is not how 1306.08(f)(1) is written. Teach the remain-electronic rule as the federal condition Connecticut already incorporated by reference.

Who may transfer — pharmacists, not a workaround intern

21 CFR 1306.25(b)(1) and 21 CFR 1306.08(f)(3) both say the transfer must be communicated directly between two licensed pharmacists. An intern is registered, not licensed as a pharmacist. That intern cannot be one of the two federal actors on a clonazepam refill transfer or an unfilled oxycodone EPCS forward.

CGS § 20-616(e) uses the same noun twice: the pharmacist transferring and the pharmacist receiving. RCSA § 20-576-9 still lets a registered intern perform contemporary pharmacy services when a pharmacist is physically present and personally supervising — pulling the profile, assembling the documentation, sitting with the pharmacist on the call. That is assistance. It is not a statute that substitutes the intern for the transferring or receiving pharmacist. RCSA § 20-576-39 already bars a technician from new verbal orders and from interpreting prescriptions; a technician taking a CS transfer is outside that regulation and outside 1306.25.

What to record — a working list

• VOID (paper) or an electronic transferred notation on the original.
• Receiving pharmacy name, address, and — for CS — DEA number.
• Receiving pharmacist name (and, for CT unfilled electronic CS, license number).
• Date of transfer and transferring pharmacist name.
• Original issue date, original Rx number, original dispensing date.
• Authorized refills, complete refill history, remaining refills.
• For unfilled EPCS: measures so the first pharmacy cannot also fill it.

Realistic Connecticut scenarios

A West Hartford patient wants her atorvastatin moved to a New Haven independent. Three of five refills remain. The transferring pharmacist cancels the original, notes New Haven’s name and today’s date, and the receiving pharmacist writes the original issue date, Rx number, first-fill date, five authorized, two used, three remaining. That is § 20-616(e).

The same patient also wants her clonazepam. Pharmacy A and Pharmacy B are unrelated. 1306.25 allows one refill transfer, pharmacist to pharmacist, VOID on A’s face, “transfer” on B’s record, remaining fills still inside the six-month / five-refill cap. A later request to send those remaining clonazepam fills to a third independent is not a second 1306.25 transfer unless the pharmacies share a real-time database — they do not.

A Stamford patient’s unfilled electronic oxycodone landed at a pharmacy that is out of stock. The patient asks that it go to a DEA-registered retail pharmacy down the street. Two pharmacists communicate; the EPCS stays electronic; Pharmacy A blocks a second fill; Pharmacy B annotates “transfer.” That is 1306.08 plus § 21a-249(l)(1)(B). Offering to “just read the CII over the phone and I’ll write it down” is the conversion DEA’s 2023 rule was written to stop. The same oxycodone after it has been filled once cannot be transferred as leftover tablets — that leftover, if any, is a partial-fill remainder (Chapter 9), not a transfer.

Official anchors

• CGS § 20-616 — subsection (e) noncontrolled transfers.
• CGS § 21a-249(l) — CIII–V transfers and unfilled electronic CII–V.
• 21 CFR 1306.25 — one-time CIII–V refill transfer; shared-database exception; two pharmacists.
• 21 CFR 1306.08 — one-time unfilled EPCS transfer for initial fill, remain electronic (2023 rule).