Exactly, it's the interpretation. It does not say that the doctor prescribing has to have seen the patient. It says the patient must have been seen. Also, even the DEA has to be careful. I see my physician. He's not on during the weekend and I need a refill on __________. (fill in the blank) Covering physician calls me in a script. He has never seen me but knows I am a patient of the doc he is covering for. That's 100% legal.

The above paragraph by the DEA is why I believe all NROPs to be illegal. However, with a record req/consult req OP you are satisfying the requirements as they are written.

A patient has a medical complaint; Backed up with records faxed to the OP

A medical history has been taken; During the consult and also when filling out the registration forms to the OP

A physical examination has been performed; by the patient's local doc

Some logical connection exists between the medical complaint, the medical history, the physical examination and the drug prescribed. That would be backed up with records and the phone consult.

So all the elemrnts have been met with a legit OP.

NROPs require NO evidence that the patient has a legit complaint or has been seen by any physician, therefore they are not in compliance.