Are blank Rx pads considered controlled substance documents that must be reported if stolen or lost?

• A. Yes
• B. No
• C. Only if blank Rx pads are used for Schedule II prescriptions
• D. Only if blank Rx pads contain patient information

Answer: (A)

Blank prescription pads for controlled substances are treated as controlled substance documents because they can be used to authorize the dispensing of CS. If such a pad is lost or stolen, it creates a real risk of diversion, even if no prescriptions were written on it. That risk triggers reporting requirements to the appropriate authorities. In practice, theft or loss of these pads should be reported to the DEA using Form 106, typically within a week of discovering the loss, and the incident should also be reported to the state board as required by state law. The need to report does not depend on the schedule of the drugs or whether patient information is on the pad; the mere loss of the blank pad itself makes it reportable.