In addition to the stated retention time, which entity may require a longer retention time for CIII-CV order documents?

• A. The supplier
• B. The purchaser
• C. State boards of pharmacy
• D. The FDA

Answer: (C)

When keeping records for controlled substances, there’s a federal baseline for how long order documents must be kept, but state rules can require more time. State boards of pharmacy oversee pharmacy practice within their states and can set longer retention periods to support state inspections, investigations, and enforcement actions. This means they may require pharmacies to hold onto CIII–CV order documents longer than the federal minimum. The FDA generally does not impose longer retention requirements at the individual pharmacy level, and while suppliers and purchasers follow the applicable federal standard, the state boards may impose the stricter, longer keeping requirements.