is gabapentin a controlled substance in washington state

Addiction. FDA warns about serious breathing problems with seizure and nerve pain medicines gabapentin (Neurontinm, Gralise, Horizant) and pregabalin (Lyrica, Lyrica CR). Pharmacies that do not dispense controlled substances to Washington State residents may complete and submit aControlled Substance Reporting Waiver(CSRW) online. Fill out the form below for: Let us walk you through the treatment process. This waiver will expire on September 30, 2021. Get Help Now For information on cookies and how you can disable them visit our Privacy and Cookie Policy. Law requires licensed pharmacies and practitioners that dispense controlled substances in the state of Washington, or to an address in the state, to electronically report prescription data. https://www.medscape.com/viewarticle/969829, https://www.pharmacytoday.org/article/S1042-0991(21)00730-1/fulltext#relatedArticles, https://medlineplus.gov/druginfo/meds/a694007.html, https://www.deadiversion.usdoj.gov/drug_chem_info/gabapentin.pdf, Gabapentin Detox: Withdrawal And Side Effects. Disclaimer. Help desk staff will communicate via email to confirm your appointment time to ensure the most efficient and respectful use of your time. Certain seizure drugs and migraine treatments are also found in Schedule V. The states that classify gabapentin as a Schedule V controlled substance include*: Gabapentin also requires reporting of prescriptions in several states, which means it is included in the states prescription drug monitoring program (PDMP) system. S3906 (ACTIVE) - Sponsor Memo. }c{h*giR.9o:+yl;Wsoza}TtU@=@v hZZ4zdo?n>l@gOC9p1. Utah. Drugs.com provides accurate and independent information on more than 24,000 prescription drugs, over-the-counter medicines and natural products. And in December, the AAN published an updated practice guideline on the management of painful diabetic polyneuropathy, which recommends gabapentin, as well as serotonin-norepinephrine reuptake inhibitors (SNRIs), sodium channel blockers, and tricyclic antidepressants for the treatment of pain in this population. Lyrica vs Gabapentin: What's the difference? But Gabapentin is not scheduled on the federal level as a controlled substance, only state level have a few states such as Kentucky, Tennessee, etc. Dispensers are required to report dispensations of gabapentin to the OR PDMP within seventy-two (72) hours after a covered substance is dispensed for each covered substance dispensed. The department will hold stakeholder meetings to gather feedback on the rules. *H S agQ$YMCmhe2l4. If you did not receive a measuring device, please ask your pharmacist for a medication-measuring device. Register for your PMP account by filling out the online registration form. The complaint should contain as much information about the missing or inaccurate record as possible to allow the PMP to follow up with the prescriber and reporting dispenser. Washington State law requires all facilities, entities, offices, or provider groups with ten(10) or more prescribers using a federally certified electronic health records (EHR) system to demonstrate that EHR system is able to fully integrate data to and from the prescription monitoring program using a mechanism approved by the Department of Health. I would worry that this would make primary care practitioners and family practice physicians, who typically prescribe these medications, less comfortable with its use, resulting in worse control of neuropathic pain and backsliding into opioid use if we make this process too complicated., Classifying gabapentin might also suggest a false equivalency with opioids, Dr. Callaghan added. We are here to provide assistance in locating an Ark Behavioral Health treatment center that may meet your treatment needs. controlled substances, or in the case of an agency application, the board shall verify agency representation. Evidence suggests that gabapentin abuse and addiction in Washington state is on the rise. At times information may be missing from, or may be incorrectly reported to, the PMP. | Neurontin Addiction Potential, mixing it with other drugs to enhance effects, going to multiple doctors for prescription refills, Medscape FDA, DEA Pushed to Make Gabapentin a Controlled Substance, Pharmacy Today More states make gabapentin a Schedule V Controlled Substance, U.S. National Library of Medicine: MedlinePlus Gabapentin, U.S. Drug Enforcement Administration (DEA) Gabapentin (neurontin). A direct phone line where you can be reached while you have access to a computer with internet connection. Addiction Resource aims to provide only the most current, accurate information in regards to addiction and addiction treatment, which means we only reference the most credible sources available. When appropriate, review the PMP report (prescribing and dispensing history) directly with the patient. But it can have dangerous effects if misused alone or with other drugs. Document your activities and decisions made based on the information you've received. All Rights Reserved. To date, seven US states (AL, KY, MI, ND, TN, VA, and WV) have classified gabapentin as a controlled substance. Stopping gabapentin suddenly can cause serious problems, including increasing your risk of seizures (if you are taking gabapentin to control seizures) or not improving your symptoms (if taking gabapentin for other indications). Price said. Upon verification of all requirements, the board shall issue the appropriate credential necessary to . The program does not collect hospital inpatient dispensing data or data from the administration of a controlled substance. Gabapentin. Zhou L, Bhattachajee S, Kwoh CK, et al. For more information, please refer to our Privacy Policy. Rates of diversion have also increased with gabapentin. Contact PMP staff members to receive more information or to begin this request process. to add Gabapentin dispensation into the CPRMS. Specifically the bill requires that facilities, entities, offices, or provider groups with ten of more prescribers, that are not critical access hospitals, must demonstrate the ability to integrate their Electronic Health Records (EHR) systems with the Prescription Monitoring Program (PMP). Unless specifically exempted or excluded or unless listed in another schedule, any material, compound, mixture, or preparation which contains any quantity of the following substances having a depressant effect on the central nervous system, including its salts: (1) Lacosamid, [(R)-2-acetoamido-N-benzyl-3-methoxy-propionamide]; (2) Pregabalin{(S)-3-(aminomethyl)-5-methylhexanoic acid}. Violators will face fines of up to $1,000. Like my colleagues, I can't think of a single patient where I've run into addiction issues or other problems aside from the known side effects of ankle swelling or a little confusion. Schedule-V controlled substance and mandated reporting to PDMP. Legal requests for PMP records may be submitted to [email protected] and must be made by court order or grand jury subpoena as outlined in RCW 70.225.040. States are now taking action to track gabapentin use through prescription monitoring programs, and some states have reclassified it as a Schedule V controlled substance. B4eQ?G%UCf I= uY>W$F,SRq_P4! %Q"6K=f: Review PMP data to ensure safe prescribing, and report missing data to the Department of Health for follow up by filing a complaint. Watch for increased sleepiness or decreased breathing when you start taking gabapentin or when the dose is increased. It's of the highest importance data on the PMP is complete and accurate. As of January 1, 2020, gabapentin will change to a covered substance for the OR PDMP. The .gov means its official. [Accessed November 17, 2020]. 3. Cleanup of hazardous substances at illegal drug manufacturing facility, Applicants for cannabis producer's, processor's, researcher's, or retailer's licenses. We do not receive any compensation or commission for referrals to other treatment facilities. The Board was made aware of incorrect communications made by a third-party vendor statingthat Ohio had made gabapentin a controlled substance. may email you for journal alerts and information, but is committed Although rates of gabapentin misuse are rising, the drug is not federally regulated as a controlled substance. The delegate employee must maintain confidentiality of the information. However, the individuals in these reports experienced symptoms after discontinuing higher-than-recommended doses of gabapentin and for uses for which the drug was not approved. The rules (WAC 246-470) took effect on August 27, 2011. The time-limited waiver will be available for those that can demonstrate an inability to integrate an EHR with the PMP due to economic hardship, technological limitations that are not reasonably in the control of the facility, entity, office, or provider group, or other exceptional circumstance demonstrated by the facility, entity, office, or provider group. . The Department of Health / Prescription Monitoring Program. For this reason, talk to your healthcare provider as soon as you know you are pregnant. Support patient safety by working to ensure accurate and complete PMP data is available to prescribers and other healthcare providers through supporting PMP reporting compliance, and by taking disciplinary action where and when necessary. They also raised concerns that classifying gabapentin as a controlled substance could backfire, leading to increased use of agents with significantly greater addictive potential, such as opioids. Gabapentin is frequently misused in combination with other drugs, particularly narcotics. Veterinarians should submit reports as often as is possible to keep the data relevant, but are required to report quarterly at minimum. This page does not provide medical advice. Pharmacies must include gabapentin in their biennial controlled substance inventory. Waiver from the integration requirement letter (PDF). This helpline is answered by Ark Behavioral Health, an addiction treatment provider with treatment facilities in Massachusetts and Ohio. This website uses cookies. Electronic communication of prescription information, Registration of department of fish and wildlife for use in chemical capture programs. Get email alerts based on your topic preferences like news releases, job openings, emergency updates and more! Healthcare providers reviewing prescribing data from the PMP from time-to-time may find records missing or data errors from the patient's PMP report. 1308.11 through 1308.15. Why Gabapentin (Neurontin) Is A Controlled Substance In Some States Understanding why gabapentin (Neurontin) is a controlled substance requires learning about the way that federal and state laws can vary regarding controlled substances. 2. . Gabapentin can be used to treat a variety of conditions, but in some cases it has the potential for abuse. It belongs to a class of drugs known as gabapentinoids, which have a chemical structure similar to the neurotransmitter gamma-aminobutyric acid (GABA). If you have or suspect you may have a health problem, you should consult your health care provider. Under the federal Controlled Substances Act, gabapentin is not listed as a controlled substance. While gabapentin is NOT considered as a controlled substance on a federal level, there are some states that reclassified the drug as a controlled substance. Dispensing is defined as providing more than a 24-hour supply of a controlled substance for immediate use. Micromedex. The program does not collect hospital inpatient . to maintaining your privacy and will not share your personal information without Waivers will be granted upon submission of an. Ann Pharmacother. Attestations last for one year and may be renewed two (2) times for a total of three (3) waivers, except in the case of other exceptional circumstance waivers. Revocation and suspension of registration. At least seven have reclassified it as a Schedule IV controlled substance. That, he and other neurologists argue, could have the unintended consequence of producing more opioid use. Veterinarians are required to report the dispensing of controlled substances (Schedule II-V) and drugs identified by the board of pharmacy under WAC 246-470-020, dispensed for more than a fourteen-day supply to Washington's Prescription Monitoring Program (PMP). Help is Available - The PMP technical support help desk at the Washington State Department of Health is available and happy to assist you with registration, access, running reports, whatever you may need. Most of the data we have are from case-controlled studies showing that gabapentin with opioids is more problematic than with opioids alone, but that is the type of article that should generate more study rather than legislating or regulating on it at the moment, Dr. Callaghan said. The use of a controlled substance is regulated by the federal government to prevent abuse or misuse. The easiest way to lookup drug information, identify pills, check interactions and set up your own personal medication records. Submitting your data directly online is quick, easy and hassle free. 100% confidential. Take other forms of gabapentin with or without food. Coming to a Cleveland Clinic location?Hillcrest Cancer Center check-in changesCole Eye entrance closingVisitation and COVID-19 information, Notice of Intelligent Business Solutions data eventLearn more. Gabapentin is a prescription medication approved by the Federal Food and Drug Administration for the treatment of neuropathic pain and epileptic disorders. Here's a good place to start. For instance, research shows gabapentin may increase the risk of sedation and overdose death when mixed with CNS depressants like opioids and benzodiazepines. 2016 Mar;50(3):229-33. doi: 10.1177/1060028015620800. Swallow tablets whole with a full glass of water. |T0 9Xe0\XR)={!,0-a,rbJB@ZyOcO};k=*Ob3C}M9\ W'K/^}4baPH Privacy Policy| Alternate Format Requests | Notice of Nondiscrimination, File Complaint About Provider or Facility, Healthcare Enforcement and Licensing Modernization Solution, Healthcare Professional Credentialing Requirements, Veterans, Service Members and their Families, Emergency Information for Specific Groups, Public Health System Resources and Services, Engrossed Substitute House Bill (ESHB) 1427 (2017). Is gabapentin a controlled substance / narcotic? Among the evidence in support of the petition, the group cited a 2019 study in The Journal of Clinical Medicine that found gabapentinoid-involved medical visits increased from 9.1 per 1,000 visits in 2003 to 34.9 in 2016, and that 98.3 percent of all gabapentin prescriptions were for off-label indications. American Society of Health-System Pharmacists. Representative samples of cannabis, useable cannabis, or cannabis-infused products. The number of individuals who have Gabapentin present in an accidental overdose is significant enough . Cleveland Clinic is a non-profit academic medical center. The effort to put gabapentin on the federal Schedule 5 list may reduce its use for pain syndromes where it could actually help, thereby leading to increased use of other agents that have more side effects and drug interactions and possibly even translate to greater use of agents that have pronounced addictive potential such as tramadol and the larger family of opioids, said Gil I. Wolfe, MD, FAAN, Irvin and Rosemary Smith Professor and Chairman of Neurology at the Jacobs School of Medicine and Biomedical Sciences at the University at Buffalo/State University of New York. 239 0 obj <>/Filter/FlateDecode/ID[<34D03281BE37664BA97036122A01F891>]/Index[213 56]/Info 212 0 R/Length 124/Prev 171370/Root 214 0 R/Size 269/Type/XRef/W[1 3 1]>>stream Effective November 18, 2019, Gabapentin is a Schedule V Controlled Substance in Alabama. Gabapentin isn't considered a controlled substance by the federal government as of July 2022. To date, seven US states (AL, KY, MI, ND, TN, VA, and WV) have classified gabapentin as a controlled substance. Thank you for your patience as we continue to update our new website. Opioid Basics. Get confidential help 24/7. endstream endobj 217 0 obj <>stream Report improper access or disclosure of information in writing to the Department of Health. These reports must be picked up in person from the department in Tumwater as program staff members must verify the requesting patient's identity in person prior to releasing any records. If youre concerned that you or a loved one are abusing gabapentin, we may be able to help. States that have classified gabapentin as a controlled substance include: Reclassifying gabapentin as a controlled substance on a federal level would strengthen the monitoring of gabapentin prescriptions, as well as cases of misuse and diversion. Eye problems: unusual eye movements, double vision. Gabapentin decreases nerve activity in the central nervous system (CNS), which is composed of the brain and spinal cord. Always take gabapentin exactly as prescribed. The department filed a CR103 with the office of the code reviser on September 7, 2021, under WSR 21-19-018, to notify the public of the adopted new rules that establish the PMP-EHR waiver criteria. Individuals experienced double vision, slurred speech, drowsiness, diarrhea and sluggishness. Individuals with chronic obstructive pulmonary disease (COPD) and the elderly are also at risk of dying from this combination. Transfer of license to produce, process, or sell cannabis. At least seven have reclassified it as a Schedule IV controlled substance. 0 Gabapentin is approved to prevent and control partial seizures, relieve postherpetic neuralgia after shingles and moderate-to-severe restless legs syndrome. The time-limited waiver will be available for those that can demonstrate an inability to comply with the mandate due to economic hardship, technological limitations, or other exceptional circumstances. Gabapentin is in a class of medications called . Have or had mood problems, depression, suicidal thoughts or behavior. Gabapentin was, for a long time, believed to be non-addictive with a low potential for abuse. The bill directs the department to develop a waiver process for this integration requirement. Hp3aM%%A5}_y])oz8YS2~KfV/z-z;MQ| ffp7`S+$EjGJ $7rEZWeE"sn=56 This information is just as important for providers in making healthcare and prescribing decisions. For the past couple of years, there has been ongoing discussion by the State of Ohio Board of Pharmacy about whether or not to make gabapentin a controlled substance. The department held a public hearing, received and reviewed comments during the public comment period, made necessary changes and filed the rules for adoption on July 27, 2011. Gabapentin may be abused for euphoria, potentiating the high from opiates, reduction of alcohol cravings, a cocaine-like high, as well as sedation or sleep. You nor your loved one are under any obligation to commit to an Ark Behavioral Health treatment program when calling our helpline. m These drugs may end up on the streets. The large majority of gabapentin prescribing is off label. Q';iA)=H5R=X5tlY*8-J`?5.$KKl%e7/g/Y[w^[B%xlx|{p|.7,i~{GBW"UoJnTs],qW_p\*2l$Y(hKD|WB//~F|7vy6BhX?M#kAvi; 4`0_Bnd@Jx=\"Bw LDir9}p Xv msh4U `@\\k1LtS{W.~M,Rs{7e.GG+T@ N-#L7+0B6Z9/3w d< IPO,Y# GABA reduces the excitability of nerve cells (neurons) in the brain, which play a role in seizures and the transmission of pain signals. Its available as 300- and 600-milligram tablets (Gralise) and 600- and 800-milligram tablets (Neurontin or generic gabapentin). 100% confidential & free. Gabapentin Information for Healthcare Professionals. Delivery of substance in lieu of controlled substance, Possession of forty grams or less of cannabis, Involving a person under eighteen in unlawful controlled substance transaction, Provisions not applicable to offenses under RCW. and transmitted securely. Swallow tablets whole with a full glass of water. A good day/time to call and connect directly with you (account owner). Provide verified information of non-compliant dispenser reporting to the Department of Health complaint intake for follow up and if necessary, license discipline. If the crime involved diversion of controlled substances, you may have a responsibility to report to the Drug Enforcement Agency (DEA). Overdoses on gabapentin have been reported. How does moving gabapentin to Schedule 5 affect pharmacies? hb```a`` BL@Q00$00;Y@THK $X dF)7dY$g! We're here to help. Program staff members work to assist system users and can do so efficiently when provided: The Washington State Prescription Monitoring Program (PMP) query portal allows healthcare professionals to query the monitoring program databases of other states using the Multi-state query function. The helpline at AddictionResource.net is available 24/7 to discuss the treatment needs of yourself or a loved one. your express consent. You may have a higher chance for dizziness, sleepiness or serious (possibly fatal) breathing problems if you take these medicines with pregabalin or gabapentin. If you're interested in receiving updates and notifications about the Prescription Monitoring Program regarding participating in the rule process, select the green Subscribe" button at the bottom of this page and add Prescription Monitoring Program as one of your DOH subscription topics, email the program, send a fax to 360-236-2901 or mail program staff at Prescription Monitoring Program, P.O. If you have reason to believe a crime has been committed, you may have a responsibility to report the crime to the local police. }i.Q~}\-?o8ATk"M,cv|N.5 I2c,DRT Bethesda, MD 20894, Web Policies Prescribers and pharmacists who have verified information to be missing or incorrect should report the discrepancy to PMP staff members, following the procedure to Report Missing or Incorrect PMP Data. The https:// ensures that you are connecting to the In February 2022, the nonprofit advocacy group Public Citizen filed a petition with the DEA and U.S. Food and Drug Administration (FDA). Here is where to find information on their requirements. Among patients with a history of substance use disorder, the question becomes Is there any pain relief medication that is relatively safe? Muscle relaxants can be abused, as can anti-anxiety medications and non-sedative hypnotics for sleep. Program rules, WAC 246-470, took effect August 27, 2011. That's a serious disservice. We don't have patients calling and requesting duplicate and triplicate prescriptions or calling and saying they're out of pills within a week, he said. Gabapentin closely resembles pregabalin, a Schedule V controlled substance, in its chemical structure and pharmaceological activity. Bookshelf In general, medications classified as Schedule V (Schedule 5) controlled substances are considered to have the lowest potential for abuse compared to other controlled schedules, but may still pose a risk of addiction or misuse. MeSH The program was created to improve patient care and to stop prescription drug misuse by collecting dispensing records for Schedule II, III, IV and V drugs, and by making the information available to medical providers and pharmacists as a patient care tool. We do not endorse non-Cleveland Clinic products or services. This is not all the information you need to know about gabapentin for safe and effective use and does not take the place of your doctors directions. This information was gathered from a published study which analyzed online information from 32 different websites. In a petition filed with the DEA and the US Food and Drug Administration (FDA) in February, the nonprofit advocacy group Public Citizen called for making that regulation federal, in an effort to stop increasing abuse and diversion. Neurontin and generic forms of Neurontin tablets may be broken into two pieces. Advertising on our site helps support our mission. qJ(Q4#[EaA]IiT0VZ`^WCC40f)B9PlIQD,M48,Xt43~] |YS;?>@,O7Q|v76_/9N_V)]XO5{r=MEVtmp?tZt 6B!OD)N/U Abuse of Opioid Alternative Gabapentin is on the Rise. That is, it may be misused by those who have a past history of opioid use disorder, or another form of drug addiction, but its rarely misused by those without that history. If you take an aluminum or magnesium-containing antacid, such as Maalox, Mylanta, Gelusil, Gaviscon, or Di-Gel, wait at least two hours before taking your next dose of gabapentin. The petition specifically cited a 2017 review in the journal European Neuropharmacology. But some states have, individually, taken action. HTML PDF. These include peer-reviewed journals, government entities and academic institutions, and leaders in addiction healthcare and advocacy. The petition also pointed to studies suggesting that both gabapentin and pregabalin, which is marketed as Lyrica and is already classified as a Schedule 5 controlled substance, pose an addiction risk for patients with current or past substance abuse. Numerous recent studies have shown that gabapentin use increases the risk of opioid overdose death. If you wish to get more information on integrating your organization's EHR through OHP you can fill out, If you wish to get more information on integrating your organization's EHR through Bamboo Health's PMP Gateway please visit the, The department may issue a waiver of this requirement to any facility, entity, office, or provider group that meets one of the qualifications for a waiver. Gabapentin is not an opioid. Epub 2022 Jan 11. Brand names of gabapentin include Horizant, Gralise and Neurontin. Please try after some time. Neuromuscular specialist Raymond Price, MD, associate professor of clinical neurology at the University of Pennsylvania and a co-author of the new AAN guideline, agrees. Seek immediate medical attention if these symptoms develop: Products that interact with gabapentin include: Avoid drinking alcohol while taking gabapentin. 21 Effective July 1, 2017, the prescribing of gabapentin is limited to authorized practitioners, defined as practitioners registered with the US DEA. CR 103 PMP-EHR integration mandate waiver rules (PDF). Mandatory reporting began on October 7, 2011. A small number of studies have reported misuse and abuse of gabapentin. 2018;11:109-116. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6103607/. To date, at least 12 states now track gabapentin within their prescription drug monitoring programs (PDMPs). Don't use the half-tablet beyond 28 days after the whole tablet was cut or broken. controlled substances from ultimate users (patients) or other individuals authorized to handle . Get help right away if you develop breathing problems. Once identity verification (KBA) and authentication processes in SAW are completed you'll be passed to the PMP for the final step. Volume:Chapter: N/A Advisory Number: N/A As such, the CPMRS look-up requirements do not apply to Gabapentin prescribing. Gabapentin abuse has been on the rise in recent years. Violations committed in or on certain public places or facilities, Opening package of or consuming cannabis, useable cannabis, cannabis-infused products, or cannabis concentrates in view of general public or public place. Review of patient controlled substance history available on the PMP is an effective evidence-based intervention for ensuring safe prescribing and patient safety. This is due to emerging patterns showing gabapentin abuse. Get useful, helpful and relevant health + wellness information. %%EOF Gabapentin may be abused for euphoria, potentiating the high from opiates, reduction of alcohol cravings, a cocaine-like high, as well as sedation or sleep. Information collected includes: the patient's name, address, and date of birth, pharmacy and prescriber information, and specific prescription information. Unauthorized use of these marks is strictly prohibited. INQUIRIES REGARDING GABAPENTIN: The BNDD has been receiving calls and emails asking if there is a plan to make gabapentin a controlled substance.The federal Drug Enforcement Administration (DEA) would schedule gabapentin first and then the state BNDD would follow suit. Federal government websites often end in .gov or .mil. Veterinarians have separate reporting requirements from pharmacies and other dispensing prescribers, which are outlined in the PMP rules and include: frequency of reporting, ability to mail/fax records and different required data fields. Data sources include IBM Watson Micromedex (updated 2 Apr 2023), Cerner Multum (updated 17 Apr 2023), ASHP (updated 10 Apr 2023) and others. In a petition filed with the DEA and the US Food and Drug Administration (FDA) in February, the nonprofit advocacy group Public Citizen called for making that regulation federal, in an effort to stop increasing abuse and diversion. HW]|_$A@^ lGQ8tg.O$l|W~_x=+9:95zJ9|s|/_2;C{p'^?ui. Centers for Disease Control and Prevention. The information provided through Addictionresource.net should not be used for diagnosing or treating a health problem or disease. Listing gabapentin as a controlled substance would enhance the ability of the government to track the misuse or abuse of gabapentin. Gabapentin enacarbil, 300- and 600-milligram extended-release tablets (Horizant). Epub 2022 Oct 27. If you have questions as a prescriber about what is or isn't required of you when prescribing controlled substances, you'll need to contact your regulatory board or commission to ensure you get the right answer based on the right set of rules. Has had enough time (more than three days) pass since dispensing to allow the record to be "live" on the PMP system. (Non-pharmacy dispensers fall under the disciplinary authority of their licensing board or commission). Use Delegates Once a prescriber has an active PMP account, the prescriber may select other active delegate staff accounts on the system to run patient PMP reports. your pharmacy does not deliver any drugs required to be reported to the PMP (schedule II, III, IV, or V controlled substances or any other drugs added by the Pharmacy Commission) to ultimate users who have a Washington State address.

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