Can I print Electronic Controlled Substance Prescriptions (EPCS)
During past inspections of retail pharmacies, I’ve frequently observed a common practice: pharmacies dispense controlled substances via electronic prescriptions, then print copies and file them alongside handwritten prescriptions. However, these printed versions often lack the federally required disclaimer—“Copy only—not valid for dispensing.”
According to 21 CFR § 1311.170(c), electronic prescription applications may generate printed copies of transmitted prescriptions only if they are clearly labeled with this disclaimer. Additionally, prescription data may be electronically transferred to medical records, and printed lists may be provided to patients—but only if those lists are clearly marked as informational and not valid for dispensing.
The DEA has consistently emphasized that once a prescription record is created electronically, it must remain in electronic form. Therefore, during inspections, Diversion Investigators are instructed to request either the original electronic record or a printed log that reflects the electronic prescriptions—not printed copies intended to mimic paper prescriptions.
Important Note: Be sure to check your state law to determine whether printed copies of electronic prescriptions are required for recordkeeping. If your state mandates printing, ensure that:
- Each printed prescription is clearly labeled “Copy only—not valid for dispensing.”
- These copies are stored separately from valid hard-copy prescriptions to avoid confusion or compliance issues.
Failure to label printed electronic prescriptions correctly may constitute a violation of federal regulations.
If you need any guidance on electronic prescriptions for controlled substances please reach out to Brinks DEA Consulting