Which statement is true regarding the original fill counting toward the 120-day supply limit for Schedule III–IV medications?

• A. It counts toward the 120-day limit
• B. It does not count toward the 120-day limit
• C. It counts as a refill only if more than 60 days supply is dispensed
• D. It resets the 6-month window

Answer: (C)

In California, the 120-day limit for Schedule III–IV drugs is based on the total days’ supply dispensed in a 6-month period. The original fill is included in that total. A useful nuance is how that original fill is counted for the purpose of the “refill” count: if the original fill is more than 60 days, the portion beyond 60 days is treated as a refill for the 120-day calculation. If the original fill is 60 days or less, it doesn’t generate a separate refill count beyond the initial supply. The 6-month window itself remains a rolling period and isn’t reset just by dispensing a new prescription. This is why the statement that the original fill counts toward the 120-day limit, but only as a refill if more than 60 days are dispensed, is the best answer.