Clinical SOP • Medication Management

Controlled Substances

Evaluate, prescribe, monitor, document, renew, and discontinue controlled medications safely while supporting legitimate patient care, reducing diversion risk, and meeting federal, state, licensing, and organizational requirements.

Applies To Authorized prescribers and designated clinical staff
Primary Goal Provide appropriate treatment while reducing patient and diversion risk
Core Standard Every prescription requires patient-specific clinical judgment

Purpose

Controlled medications require enhanced clinical review, documentation, monitoring, patient education, prescribing authority, and diversion prevention.

Controlled substances may be prescribed only by a provider who is appropriately licensed, registered, credentialed, and authorized for the medication, schedule, patient location, and type of clinical care being provided.

A controlled-substance prescription must never be issued solely because the patient requests it, previously received it, reports losing it, or states that another clinician normally prescribes it.
The prescribing provider is responsible for confirming that the medication serves a legitimate medical purpose and is issued within the provider’s usual professional practice.

Scope

Schedule II Medications

Includes medications with accepted medical uses and a high potential for misuse or dependence. Schedule II prescriptions are not processed as routine refills.

Schedule III–V Medications

Includes controlled medications with varying levels of misuse and dependence risk. Prescribing and renewal limits remain subject to law, clinical judgment, and TNC policy.

Opioid Medication

Includes opioid analgesics and other opioid products requiring medication-specific risk assessment, monitoring, and patient education.

Stimulant Medication

Includes controlled stimulant medication used for clinically supported diagnoses and managed within the provider’s authorized scope.

Benzodiazepines and Sedatives

Includes controlled medications that may cause sedation, impairment, respiratory depression, tolerance, or withdrawal.

Other Controlled Medication

Includes testosterone products, sleep medications, weight-management medications, and other products classified as controlled substances.

Roles and Responsibilities

Prescribing Provider

Completes the clinical evaluation, confirms prescribing authority, reviews monitoring information, checks the applicable PDMP, makes the prescribing decision, and documents the treatment plan.

Medical Assistant

May collect medication history, vital signs, screening information, pharmacy details, agreement status, testing status, and patient concerns for provider review.

Clinical Support Staff

May receive and route requests, collect outside records, assist with authorized monitoring workflows, and communicate the provider’s documented instructions.

Clinical Leadership

Supports training, audit review, incident escalation, diversion concerns, policy implementation, and unresolved controlled-substance workflow concerns.

Staff may not use a provider’s electronic credentials, DEA information, signature, authentication method, or RXNT prescribing access to issue or authorize a controlled-substance prescription.

Required Prescriber Authority

Active Professional License

The provider must hold an active license that permits the clinical evaluation and prescribing activity.

DEA Registration

The provider must maintain an active DEA registration appropriate for the controlled substances prescribed and required practice location.

State Prescribing Authority

The provider must meet applicable state prescribing, supervisory, collaborative, furnishing, and controlled-substance requirements.

Location Authority

The provider must be authorized to treat and prescribe for the state where the patient is physically located.

Medication Schedule

The provider’s authority must include the specific controlled medication and schedule being considered.

TNC Credentialing and Privileges

The provider must remain approved to provide the relevant service within TNC’s credentialing and clinical structure.

Required Clinical Evaluation

Patient Identification

Verify the patient with two identifiers and confirm the correct RXNT chart, encounter, provider, and clinic location.

Diagnosis and Indication

Confirm a clinically supported diagnosis or indication that is within the provider’s scope and treatment plan.

History and Examination

Complete the history, examination, screening, and clinical assessment required for the medication and condition.

Medication Reconciliation

Review prescriptions, controlled medications, over-the-counter products, supplements, outside medications, and actual patient use.

Allergy Review

Review allergies, prior reactions, intolerances, and conflicting information.

Substance-Use History

Assess relevant alcohol, cannabis, illicit substance, prescription misuse, overdose, treatment, and recovery history.

Mental-Health Review

Assess relevant anxiety, depression, mania, psychosis, suicidal thoughts, behavioral concerns, and outside behavioral-health care.

Medical Risk Factors

Review respiratory disease, sleep apnea, pregnancy, renal or hepatic disease, cardiovascular risk, falls, cognitive impairment, and other medication-specific risks.

Prior Treatment

Review non-controlled alternatives, prior controlled medications, treatment response, side effects, dose changes, and reasons for discontinuation.

Outside Prescribers

Identify other clinicians prescribing controlled medications or treating the same condition.

PDMP Review

Review the applicable prescription monitoring program as required by law, professional standards, medication type, and TNC policy.

Monitoring Requirements

Confirm required visits, laboratory testing, vital signs, screening, toxicology testing, medication agreements, and other monitoring.

Standard Controlled-Substance Workflow

1

Verify the Patient and Encounter

Confirm the patient’s full name, date of birth, provider, location, appointment type, and date of service.

2

Confirm Prescribing Authority

Confirm the provider is licensed, registered, credentialed, and authorized for the medication, schedule, patient state, and clinical service.

3

Complete the Clinical Evaluation

Establish the diagnosis, indication, treatment goals, expected benefit, patient-specific risk, and available alternatives.

4

Reconcile Medications

Review all active medications, controlled substances, sedating medications, outside prescriptions, supplements, and actual use.

5

Review the PDMP

Review the applicable state monitoring program and evaluate prescribers, pharmacies, dates, quantities, overlapping medication, early fills, and other relevant findings.

6

Complete Risk Assessment

Assess misuse risk, overdose risk, medication interactions, substance-use history, mental-health concerns, and ability to follow the treatment plan.

7

Review Required Agreements and Monitoring

Confirm the controlled-substance agreement, informed consent, toxicology testing, pill counts, follow-up visits, or other required elements when applicable.

8

Consider Non-Controlled Alternatives

Evaluate whether non-controlled medication, therapy, behavioral intervention, specialty care, physical treatment, or another option may safely meet the treatment goal.

9

Select the Medication and Dose

Choose the appropriate medication, formulation, strength, dose, route, frequency, duration, quantity, and monitoring plan.

10

Complete the Safety Review

Review allergies, interactions, duplicate therapy, pregnancy concerns, contraindications, and overlapping sedating medications.

11

Confirm the Pharmacy

Verify the pharmacy name and location before transmission and review whether the patient is following any required pharmacy limitation.

12

Educate the Patient

Explain benefits, risks, impairment, storage, disposal, interactions, overdose concerns, treatment expectations, and refill rules.

13

Issue the Prescription

The authorized provider personally reviews, signs, authenticates, and transmits the prescription through the approved prescribing process.

14

Document the Treatment Plan

Document the clinical indication, risk-benefit decision, PDMP review, medication details, education, monitoring, and follow-up.

15

Schedule Follow-Up

Establish the next visit, testing, monitoring, specialist care, and circumstances requiring earlier evaluation.

Prescription Monitoring Program Review

Patient Match

Confirm the report belongs to the correct patient and review possible alternate names or demographic variations.

Medication History

Review controlled medications, quantities, dates, days supplied, and medication combinations.

Prescribers

Identify the number and type of prescribers involved in the patient’s controlled-medication care.

Pharmacies

Review pharmacy use and identify unexpected or unexplained changes.

Timing

Review early fills, overlapping supplies, recently issued prescriptions, and timing inconsistent with the reported history.

Medication Combinations

Review combinations that increase sedation, impairment, overdose, or other clinical risk.

A concerning monitoring-program finding does not automatically establish misuse or diversion. The provider must clarify the information, assess the patient, document the clinical reasoning, and determine an appropriate plan.

Controlled-Substance Agreement

A controlled-substance agreement may be required based on medication type, duration of treatment, provider judgment, state requirements, and TNC policy.

One Coordinating Prescriber

The patient should understand which clinician coordinates the controlled-substance treatment plan.

Pharmacy Expectations

The patient should understand any requirement to use a designated pharmacy or notify TNC before changing pharmacies.

Medication Security

Medication must be secured from children, visitors, household members, theft, and unauthorized access.

No Sharing or Selling

The patient must not share, trade, sell, or provide medication to another person.

Monitoring Participation

The patient must complete required visits, laboratory testing, toxicology testing, pill counts, referrals, and other monitoring.

Medication Changes

The patient should not independently increase, decrease, stop, restart, combine, or replace medication.

Lost or Stolen Medication

The agreement should explain that replacement is not guaranteed and remains subject to provider review and applicable policy.

Early Requests

Early prescription requests are reviewed individually and may be denied or require additional assessment.

Outside Controlled Medication

The patient must report controlled substances received from emergency, dental, surgical, specialist, or other outside care.

Agreement Violation

Failure to follow the treatment plan may result in additional monitoring, modification, tapering, discontinuation, or referral.

Ongoing Monitoring

Clinical Benefit

Confirm that the medication supports measurable improvement in symptoms, function, safety, or another defined treatment goal.

Adverse Effects

Assess sedation, falls, constipation, mood changes, cardiovascular symptoms, sleep concerns, appetite changes, and other medication risks.

Medication Adherence

Assess whether the patient takes the medication as prescribed and whether doses are missed, changed, shared, or used differently.

PDMP Review

Repeat monitoring-program review according to applicable law, patient risk, medication type, and TNC policy.

Toxicology Testing

Complete testing when clinically indicated or required and review results in context rather than using results without clinical interpretation.

Pill Counts

Complete medication counts when required by the provider, agreement, clinical concern, or policy.

Vital Signs and Laboratory Testing

Monitor blood pressure, pulse, weight, laboratory values, or other medication-specific measures.

Outside Care

Review emergency visits, hospitalizations, specialist treatment, dental care, surgery, and outside controlled prescriptions.

Risk Changes

Reassess pregnancy, substance use, mental health, overdose risk, cognition, respiratory disease, housing security, and other changes.

Continued Need

Reassess whether the medication remains necessary and whether the benefits continue to outweigh the risks.

Prescription and Renewal Requests

1

Verify the Patient

Confirm full name, date of birth, callback information, medication, strength, directions, and pharmacy.

2

Check for Duplicate Requests

Review existing tasks, portal messages, pharmacy requests, prescriptions, and telephone encounters before creating a new task.

3

Review the Last Prescription

Confirm medication, strength, quantity, directions, date issued, expected supply, pharmacy, and prescription status.

4

Review Follow-Up and Monitoring

Confirm required visits, agreements, PDMP review, testing, vital signs, specialist care, and other monitoring.

5

Identify Special Circumstances

Document early requests, lost or stolen medication, travel, pharmacy shortage, hospitalization, outside prescriptions, dose differences, or adverse effects.

6

Route to the Prescriber

Route the complete request to the responsible provider without promising approval or a specific completion time.

7

Communicate the Decision

Communicate approval, denial, appointment requirements, monitoring instructions, medication changes, or referral exactly as documented.

8

Close Only After Resolution

Confirm the prescription was transmitted or the request was otherwise resolved before closing the workflow.

Schedule II medications cannot be processed as refills. A new prescription and complete prescriber review are required.

Early Refill Requests

An early request must be documented and routed for provider review. Approval is not guaranteed and should not be promised by staff.

Collect the reason for the request, remaining quantity, last dose, pharmacy information, travel dates when applicable, and any relevant supporting information.
Review prescription dates, expected supply, PDMP information, pharmacy history, recent dose changes, and prior early requests before a decision is made.
Staff may not instruct the patient to take fewer doses, split medication, borrow medication, use another person’s prescription, or change the dosing schedule while waiting for review.

Lost, Stolen, Damaged, or Destroyed Medication

1

Document the Report

Record what occurred, when it occurred, medication information, quantity believed missing, and remaining supply.

2

Do Not Promise Replacement

Explain that replacement requires provider review and may not be approved.

3

Collect Supporting Information

Obtain police-report information, pharmacy information, travel details, damaged packaging, or other documentation when requested.

4

Review History

Review prior lost, stolen, damaged, early, or replacement requests and applicable monitoring information.

5

Route for Provider Decision

The provider determines whether to deny, replace, modify, taper, monitor, refer, or otherwise address the request.

Pharmacy Shortage or Transfer Request

When the pharmacy cannot fill a prescription, verify whether the prescription remains active, partially filled, transferred, canceled, or unavailable before taking additional action.

Do not issue or request a duplicate prescription without determining the status of the original prescription.
Pharmacy transfer options depend on the prescription type, pharmacy systems, applicable law, and whether the original prescription is eligible for transfer. Route unresolved issues to the provider or pharmacist.

Concerning Findings

Multiple Prescribers

Unexpected controlled prescriptions from multiple clinicians without clear care coordination.

Multiple Pharmacies

Frequent unexplained pharmacy changes or inconsistent pharmacy use.

Repeated Early Requests

Repeated reports of running out early or requesting medication before the expected date.

Repeated Lost or Stolen Medication

Multiple reports of medication loss, theft, destruction, spilling, or missing quantities.

Unexpected Toxicology Result

Results inconsistent with the prescribed treatment plan or reported substance use.

Medication Alteration

Evidence that prescriptions, containers, labels, pill quantities, or records may have been altered.

Escalating Dose Requests

Repeated requests for higher doses without a supporting clinical assessment.

Unsafe Medication Combination

Concurrent controlled or sedating medications that may increase impairment or overdose risk.

Agreement Concerns

Missed appointments, declined monitoring, unauthorized medication use, or failure to follow the treatment plan.

Behavioral Concern

Threats, coercion, prescription manipulation, suspected diversion, or another significant safety concern.

Concerning findings require clinical review, clarification, and documentation. Avoid accusatory language and do not diagnose misuse or diversion based on a single finding without appropriate evaluation.

Provider Response Options

Continue Treatment

Continue when benefits remain clinically meaningful and risks remain appropriately managed.

Modify Treatment

Change the medication, dose, quantity, frequency, monitoring plan, or follow-up interval.

Increase Monitoring

Require more frequent visits, PDMP review, toxicology testing, pill counts, or care coordination.

Use a Limited Supply

Authorize a limited quantity while additional assessment, records, monitoring, or follow-up is completed.

Decline the Request

Deny a prescription or replacement when it is not clinically appropriate or required information is unavailable.

Taper or Discontinue

Establish an appropriate provider-directed plan when continued treatment is no longer safe or beneficial.

Refer to a Specialist

Refer for pain management, psychiatry, addiction treatment, behavioral health, sleep care, or another specialty when appropriate.

Coordinate With Outside Care

Contact outside prescribers, pharmacies, hospitals, or specialists to clarify overlapping treatment.

Tapering or Discontinuation

Tapering or discontinuation is a clinical decision made by the prescribing provider based on medication type, duration of use, patient risk, treatment response, withdrawal risk, and the reason for the change.

Staff must not instruct a patient to abruptly stop, reduce, increase, restart, or taper a controlled medication without documented provider direction.
The treatment plan should address the taper schedule when appropriate, withdrawal symptoms, emergency warning signs, alternative treatment, monitoring, and follow-up.

Patient Education

Medication Purpose

Explain the condition being treated and the expected treatment goal.

Directions

Review the dose, route, frequency, timing, duration, and maximum permitted use.

Impairment

Explain medication-specific driving, operating-equipment, work, fall, and decision-making risks.

Medication Interactions

Review important interactions with alcohol, sedatives, opioids, stimulants, sleep products, cannabis, and other medications.

Overdose and Emergency Signs

Explain medication-specific emergency symptoms and when to call 911.

Secure Storage

Instruct the patient to store medication securely and away from children and unauthorized individuals.

No Sharing

Explain that controlled medication must never be shared, sold, traded, or provided to another person.

Safe Disposal

Explain approved medication take-back or product-specific disposal options.

Renewal Expectations

Explain appointment, testing, monitoring, pharmacy, timing, and controlled-medication request requirements.

Teach-Back

Ask the patient to explain how they will use, store, and monitor the medication.

Suspected Diversion or Fraud

Report suspected prescription alteration, identity misuse, diversion, theft, unauthorized access, credential misuse, forged communication, or fraudulent prescribing activity to clinical and organizational leadership immediately.

Preserve relevant messages, prescriptions, pharmacy communication, PDMP information, documents, access records, and other supporting information.
Do not independently confront the suspected individual, alter the medical record, delete communication, promise a prescription, or conduct an unauthorized investigation.

Medication Error or Unauthorized Prescription

1

Protect the Patient

Determine whether the patient received or used the medication and assess whether urgent clinical action is required.

2

Notify the Provider and Leadership

Escalate the event immediately to the prescribing provider and appropriate organizational leadership.

3

Contact the Pharmacy When Directed

Clarify whether the prescription was received, filled, transferred, canceled, or dispensed.

4

Correct the Active Treatment Plan

The provider determines whether the prescription must be canceled, replaced, modified, or clinically addressed.

5

Document the Clinical Event

Document patient assessment, provider instructions, pharmacy communication, treatment actions, and follow-up.

6

Complete Internal Reporting

Complete the required safety, compliance, privacy, or security reporting process separately from the medical record.

Do and Do Not

Always Do

  • Verify the correct patient and encounter.
  • Confirm the provider’s prescribing authority.
  • Complete an appropriate clinical evaluation.
  • Reconcile all medications and controlled substances.
  • Review the applicable PDMP when required.
  • Assess misuse, interaction, and overdose risk.
  • Review required agreements and monitoring.
  • Confirm the correct medication and pharmacy.
  • Educate the patient about safety and storage.
  • Document the risk-benefit decision.
  • Track requests until final resolution.
  • Report suspected diversion or credential misuse.

Never Do

  • Promise a controlled prescription will be approved.
  • Process Schedule II medication as a refill.
  • Use another person’s prescribing credentials.
  • Share provider authentication information.
  • Issue a prescription without a legitimate clinical purpose.
  • Ignore PDMP or medication-history concerns.
  • Change the dose or quantity without provider authorization.
  • Promise replacement of lost or stolen medication.
  • Create duplicate prescriptions without checking status.
  • Tell a patient to borrow or share medication.
  • Alter documentation to hide an error.
  • Ignore suspected diversion, fraud, or unauthorized access.

RXNT Documentation

Detailed screenshots belong in the RXNT Center. Use the following documentation standard for controlled-substance workflows.

Patient and Encounter

Confirm the patient, date of birth, provider, location, encounter, and date of service.

Clinical Indication

Document the diagnosis, symptoms, functional concerns, examination, and treatment goals.

Medication Reconciliation

Update active controlled substances, other medications, outside prescriptions, and actual patient use.

PDMP Review

Document completion and relevant clinical findings according to applicable requirements.

Risk Assessment

Document substance-use history, mental-health concerns, interactions, overdose risk, and relevant medical conditions.

Agreement and Monitoring

Document agreement status, toxicology testing, pill counts, laboratory testing, vital signs, and other monitoring.

Prescription Details

Confirm medication, formulation, strength, dose, route, frequency, duration, quantity, and pharmacy.

Clinical Decision

Document the expected benefit, identified risks, alternatives considered, and reason for continuing or changing treatment.

Patient Education

Document safety, impairment, interactions, storage, disposal, monitoring, and request expectations.

Follow-Up Plan

Document required appointments, monitoring, testing, referrals, and conditions requiring earlier evaluation.

Prescription Status

Confirm whether the prescription was transmitted, canceled, replaced, transferred, denied, or otherwise resolved.

Patient Communication

Document the outcome, communication method, instructions, and patient understanding when applicable.

RXNT screenshots belong in the RXNT Center. This page remains the master Controlled Substances SOP.

Employee Competency

Employees should demonstrate each controlled-substance responsibility assigned to their role.

Verifies the correct patient and encounter.
Explains provider authorization requirements.
Completes accurate medication reconciliation.
Identifies required PDMP and monitoring review.
Recognizes early and replacement requests.
Routes requests without promising approval.
Protects provider credentials and prescribing access.
Recognizes concerning medication combinations.
Escalates suspected diversion or prescription fraud.
Communicates provider decisions accurately.
Documents controlled-substance workflows in RXNT.
Explains the limits of support-staff authority.