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Elizabeth Willis, Chief, Drug Operations,
DEA Office of Diversion Control
Records Comments About On-Line Pharmacies

The issue of consumers purchasing controlled substances over the Internet has serious legal and public health implications. It is a method of self-medication without the safeguards of an experienced medical diagnosis and monitoring by a trained and licensed physician. Just as we don't allow consumers to walk into a pharmacy and purchase controlled substances without a valid prescription, we don't allow this to take place on the Internet.

Many people have asked about on-line prescribing. A prescription for a controlled substance is valid only if it is written by a DEA-registered practitioner acting within the course of professional practice. This includes having an established doctor-patient relationship based upon a medical history, a physical exam and diagnosis. There must be a logical connection between the medical diagnosis and the controlled substance prescribed. A prescription written based soley upon an on-line questionnaire does not meet these requirements. It is not a valid prescription and the distribution of any controlled substance pursuant to an invalid prescription is illegal.

The responsibility for writing a valid prescription for controlled substances rests primarily upon the physician. It is his or her obligation to ensure that controlled substances are prescribed for valid medical reasons and according to state and federal regulations. However, there is also a corresponding liability that rests on pharmacists to ensure that they dispense controlled substances only pursuant to a valid prescription. If the pharmacist fills a prescription knowing that it is based soley upon a 2-minute telephone consultation or on-line questionnaire, the pharmacist is also violating the law.

These drug products are controlled for a reason. They have been determined to have potential for abuse and addiction. When prescribed, dispensed and used properly, controlled substances are effective in treating a variety of illnesses and medical conditions. But when they are not used according to a physician's direction for a valid medical purpose, they can cause overdose and death.

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