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Prescription Drug Reform Act in Relation to Veterinarians
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1.  The Prescription Drug Reform Act signed into law in 2012 contained five parts:

A. I-STOP (Internet System to Track Over-Prescribing) – Requires practitioners and pharmacists to report any dispensing of controlled substances in "real time”; requires practitioners to consult the registry prior to prescribing or dispensing and Schedule II – IV Controlled Substances. Veterinarians are exempted from these requirements of the law.
B.  Electronic Prescribing – Provides for Department of Health to enact regulations providing for electronic prescribing of controlled substances (proposed regulations were published in the Jan. 16, 2013, State Register); currently prescriptions for controlled substances may not be issues electronically. As of Feb. 31, 2014, electronic prescribing will be mandatory for all practitioners - Veterinarians  are exempted from the mandatory electronic prescribing provisions of the law.
C.  Changes in Controlled Substance Schedules – This is the section that made Tramadol a Schedule IV controlled substance (Tramadol was not previously a controlled substance) and changed hydrocodone from a Schedule III controlled substance to a Schedule II controlled substance, effective Feb. 23, 2013. Other changes in schedules for controlled substances went into effect on Nov. 25, 2012.
D.  Prescription Pain Medication Awareness Program – Provides for the formation of a workgroup of practitioners, pharmacists, consumer advocates, addiction treatment providers, law enforcement agencies and NYSDOH to study and issue additional recommendations for pain management and the use of controlled substances; specifically tasked with issuing recommendations for continuing education for practitioners.

E.  Safe Disposal Program – Provides for local police departments to establish safe disposal sites to be used by consumers (not by practitioners) with unused controlled substances. 
2.  Recommendations for veterinarians now required to comply with controlled substance regulations when administering and dispensing Tramadol:

  • Orders for Tramadol must be retained with the veterinary hospital’s controlled substance records. 
  • When received, the amount of Tramadol received must verified and logged into the veterinary hospital’s controlled substance log. 
  • Tramadol must be kept in a secure location as required for all controlled substances. 
  • Every use of Tramadol in the hospital (administration of the drug) must be recorded in the controlled substance log under the section for this drug. 
  • Every time Tramadol is dispensed, the dispensing must be recorded in the controlled substance log under the section for this drug. 
  • Tramadol dispensed to a client/patient is limited to a 30-day supply of the drug at the maximum daily dosage determined by the practitioner to be appropriate, and recorded on the label attached to the drug container delivered to the client. 
  • Tramadol prescribed for a patient is limited to a 30-day supply of the drug at the maximum daily dosage determined by the practitioner to be appropriate, and recorded on the prescription; refills are limited to five. 
  • All dispensing of Tramadol must be reported by the veterinary hospital to NYSDOH through the electronic reporting system set up in 2006. This system requires the hospital to establish a Health Commerce System (HCS) Account (formerly called an HPN or Health Provider Network Account). Veterinarians who do not currently have an HCS account can establish one by following instructions on the NYSDOH website at and applying for a HCS Medical Professions account.  Monthly reports of all controlled substances dispensed at the veterinary hospital (including Tramadol dispensed since Feb. 23, 2013) must be submitted to NYSDOH by the 15th of the following month. If a veterinary hospital does not have an HCS account but does dispense Tramadol, an account must be opened in time for the hospital to make a first report of dispensed Tramadol by March 15. All controlled substances dispensed in February should be included on one monthly report.

Controlled Substances

Item Name Posted By Date Posted
General Questions on I-Stop Provisions Link Administration 8/27/2013
Obtaining a HCS account for unlicensed staff PDF (1003.02 KB) Administration 8/27/2013
How to apply for a HCS account PDF (909.44 KB) Administration 8/27/2013
NYSVMS provides additional information on BNE dail Link Administration 8/27/2013
BNE doesn't grant veterinary exemption  Link Administration 8/26/2013
Update on PPA Link Administration 8/23/2013
Disposal and Destruction of Controlled Substances Link Administration 8/21/2013
DOH Guide to Online CSI Program Link Administration 8/21/2013
Changes to CS Schedule - February 2013 - Tramadol Link Administration 8/21/2013


More InfoHide Info ]
Contains Knowledge Center articles related to pharmacy, pet medications, compounding, controlled substances and other topics related to drugs.
Item Name Posted By Date Posted
Online Pharmacies PDF (59.44 KB) Administration 10/7/2016
Partnering Online Pharmacies PDF (50.21 KB) Administration 10/7/2016
Electronic Prescriptions PDF (177.27 KB) Administration 3/31/2015
Can unlicensed staff prepare/dispense prescription Link Administration 12/12/2014
Official NYS prescription pad Link Administration 4/22/2014
Online Pharmacy Q&A PDF (46.9 KB) Administration 4/17/2014
Prescription Drug Reform Act (I-STOP) Link Administration 8/21/2013
Prescription Drug FAQ Link Administration 8/21/2013
Federal and State Regulations on Compounding Link Administration 8/21/2013
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