Arizona’s guidelines for prescribing controlled substances cap new Schedule II opioid prescriptions at 90 morphine milligram equivalents (MME) per day, limit initial fills to a five-day supply, and require prescribers to check the state prescription monitoring database, consult a pain specialist before exceeding the daily cap, and co-prescribe naloxone whenever a patient goes above it. These rules apply to every healthcare professional authorized to prescribe controlled substances in the state, with defined exceptions for surgical recovery, cancer, hospice, traumatic injury, and chronic intractable pain.
Five-Day Supply Limit on Initial Prescriptions
A first-time Schedule II opioid prescription cannot exceed a five-day supply.1Arizona State Board of Pharmacy. Opioid Epidemic Act FAQs A prescription counts as “initial” when the patient has not filled any portion of the same prescription in the previous 60 days.
Several patient situations fall outside the five-day ceiling:2Arizona Legislature. Fact Sheet for SB 1001
- Post-surgical prescriptions, which may cover up to 14 days.
- Patients being actively treated for cancer.
- Patients with a traumatic injury other than a surgical procedure.
- Patients in hospice, palliative, or end-of-life care.
- Patients receiving burn treatment or skilled nursing care.
Compliance with the five-day rule is the prescriber’s responsibility. Pharmacists are not required to verify it independently.3Arizona Legislature. Arizona Revised Statutes Title 32 – Section 32-3248
The 90 MME Per Day Cap
Separately from supply duration, prescribers may not issue a new opioid prescription exceeding 90 MME per day for patients outside a healthcare institution.4Arizona Legislature. SB 1324 – Arizona Revised Statutes 32-3248.01 The cap targets new outpatient prescriptions. Patients already admitted to a hospital or other healthcare institution are not subject to the ceiling during their stay.
Exceptions to the 90 MME Cap
The statute recognizes categories where the daily cap does not apply:4Arizona Legislature. SB 1324 – Arizona Revised Statutes 32-3248.01
- Continuation of a prescription the patient filled within the previous 60 days.
- Opioids whose FDA-approved labeling sets a maximum total daily dose above 90 MME.
- Post-surgical prescriptions, capped at a 14-day supply.
- Active cancer diagnosis or traumatic injury (excluding surgical procedures).
- Hospice, palliative, or end-of-life care.
- Burn treatment, skilled nursing care, or hospitalization.
- Medication-assisted treatment for substance use disorders, including buprenorphine-based therapies.
- Chronic intractable pain.
The chronic intractable pain exception is the pathway most long-term pain patients encounter. It requires the prescriber to have an established treatment relationship with the patient, including a thorough history and physical examination, and to document that lower dosages were tried and proved inadequate.1Arizona State Board of Pharmacy. Opioid Epidemic Act FAQs
Consultation Before Exceeding 90 MME
When a prescriber believes a patient needs more than 90 MME per day and no listed exception applies, an outside consultation is required before the prescription can be written. The prescriber must consult either a physician board-certified in pain management or an opioid assistance and referral call service designated by the Arizona Department of Health Services.5Arizona Legislature. SB 1162 Summary
The consultation can occur by phone or telehealth. If the consulting physician or referral service agrees the patient needs the higher dose, the prescriber is authorized to write it.5Arizona Legislature. SB 1162 Summary
If the consulting physician is unavailable within 48 hours of the request, the prescriber may go ahead and write the prescription for the amount they believe the patient needs. The consultation still has to happen afterward.4Arizona Legislature. SB 1324 – Arizona Revised Statutes 32-3248.01
A physician who is already board-certified in pain management can prescribe above 90 MME without consulting anyone else.1Arizona State Board of Pharmacy. Opioid Epidemic Act FAQs
Mandatory Naloxone Co-Prescribing
Any time a patient receives an opioid prescription exceeding 90 MME per day, whether through an exception or after a consultation, the prescriber must also prescribe naloxone hydrochloride or another FDA-approved opioid antagonist designed to reverse overdoses.1Arizona State Board of Pharmacy. Opioid Epidemic Act FAQs This requirement holds regardless of which exception brought the patient above the threshold.
Prescription Monitoring Program Checks
Before writing a Schedule II, III, or IV opioid or benzodiazepine prescription, a prescriber must pull a patient utilization report from Arizona’s Controlled Substances Prescription Monitoring Program (CSPMP) covering at least the previous 12 months.6Arizona Legislature. Arizona Code 36-2606 The check happens at two points: the start of each new course of treatment, and at least quarterly for as long as the prescription remains part of the patient’s regimen.
Pharmacists have a parallel obligation when dispensing a Schedule II controlled substance. They must register with the CSPMP and pull a 12-month utilization report at the start of each new course of treatment. Exceptions apply to patients in hospice care, palliative care, cancer treatment, and dialysis.
Penalties for Violations
Violations of Arizona’s opioid prescribing rules are treated primarily as unprofessional conduct, which triggers licensing consequences rather than criminal charges. The Opioid Epidemic Act amended the unprofessional conduct definitions for physicians, osteopathic physicians, dentists, podiatrists, and physician assistants to specifically include inappropriate dispensing of Schedule II opioids.7Arizona Legislature. Chapter 0001 – SB 1001 Session Law
An unprofessional conduct finding exposes a prescriber to the full range of board disciplinary actions: censure, civil penalties, probation, license suspension, or revocation. Discipline is handled by whichever board oversees the prescriber’s profession. Separately, the law carries criminal penalties for fraudulent schemes involving opioid manufacture, sale, or marketing worth $100,000 or more, where convicted individuals face mandatory imprisonment without eligibility for suspension of sentence or probation.7Arizona Legislature. Chapter 0001 – SB 1001 Session Law
Federal Rules That Apply Alongside Arizona Law
Arizona’s requirements sit on top of federal rules. Two federal developments matter in 2026.
DEA Telehealth Flexibilities Through 2026
The Ryan Haight Act generally requires at least one in-person medical evaluation before a practitioner can prescribe controlled substances remotely. A temporary DEA rule extends COVID-era telehealth flexibilities through December 31, 2026, allowing DEA-registered practitioners to prescribe Schedule II through V controlled substances via telehealth without a prior in-person visit, provided the prescription serves a legitimate medical purpose and uses a qualifying telecommunications system.8Federal Register. Fourth Temporary Extension of COVID-19 Telemedicine Flexibilities for Prescription of Controlled Medications The flexibility expires at year’s end unless extended again.
Medicare Part D Opioid Safety Edits
For patients on Medicare Part D, plan-level edits add another compliance layer. In 2026, Part D sponsors are expected to implement a care coordination edit at the same 90 MME per day threshold Arizona uses, along with a hard edit limiting initial opioid fills for opioid-naive patients to a seven-day supply.9CMS. CY 2026 Medicare Part D Opioid Safety Edits – Submission Instructions Part D plans must exempt beneficiaries in long-term care, hospice, palliative or end-of-life care, those with sickle cell disease, and those being treated for cancer-related pain. These pharmacy-level blocks can require prior authorization or override codes to resolve.
Tapering Existing Patients
Arizona’s prescribing limits do not authorize abrupt discontinuation of patients already on long-term opioid therapy. FDA-required labeling directs prescribers not to suddenly stop opioids in physically dependent patients, citing reports of withdrawal, uncontrolled pain, psychological distress, and suicide following abrupt cutoffs.10U.S. Food and Drug Administration. FDA Identifies Harm Reported From Sudden Discontinuation of Opioid Pain Medicines The general recommendation is to reduce doses by no more than 10 to 25 percent every two to four weeks, with individual adjustment.
The CDC’s 2022 Clinical Practice Guideline recommends that patients on long-term opioid therapy of a year or more be tapered over several months to years, with 10 percent per month or slower as the preferred pace.11Centers for Disease Control and Prevention. CDC Clinical Practice Guideline for Prescribing Opioids for Pain – United States, 2022 The guideline calls for monthly follow-ups during tapering and instructs clinicians to pause or slow the taper if a patient develops increased pain or withdrawal symptoms. It also explicitly warns against patient abandonment.
For existing Arizona patients above 90 MME, the practical pathway is the 60-day continuation exception combined, where appropriate, with the consultation process to document a clinically supported plan.