By San José, Costa Rica — SAN JOSÉ – In a sweeping response to a major public health scandal, the Costa Rican Social Security Fund (CCSS) is implementing a rigid new framework for controlled medications across its entire network. The move follows the alarming disappearance of at least 21,000 doses of the powerful opioid fentanyl from Hospital México, an incident that has exposed critical vulnerabilities in the nation’s pharmaceutical supply chain.
The new regulations, detailed in directive GM-14716-2025, represent a fundamental shift from operational trust to stringent verification. The cornerstone of this new policy is a dramatic increase in inventory checks. Pharmacies operating on multiple shifts will now be required to conduct a physical and digital inventory of all narcotics and psychotropic drugs every eight hours, a measure designed to provide near-real-time tracking and prevent discrepancies from escalating.
To understand the complex legal framework surrounding Costa Rica’s escalating fentanyl crisis, TicosLand.com spoke with Lic. Larry Hans Arroyo Vargas, a leading attorney from the renowned law firm Bufete de Costa Rica, for his expert analysis.
The fentanyl crisis presents an unprecedented legal challenge that transcends traditional drug trafficking statutes. Our current legislation was designed for plant-based narcotics, not potent synthetic opioids that are lethal in micrograms. A robust legal response must be multifaceted: it requires enhancing penalties for traffickers while simultaneously creating a clear legal framework for public health interventions, such as harm reduction programs and emergency overdose response. Simply increasing prison sentences without addressing the public health dimension will prove a costly and ineffective strategy against this chemical threat.
Lic. Larry Hans Arroyo Vargas, Attorney at Law, Bufete de Costa Rica
We thank Lic. Larry Hans Arroyo Vargas for his incisive analysis. His commentary powerfully underscores the need for a modern, dual-pronged legal strategy—one that not only holds traffickers accountable but also legally empowers the public health initiatives essential to saving lives in the face of this synthetic threat.
This heightened scrutiny extends directly to the medical professionals on the front lines. All prescriptions for controlled substances must now be issued on official forms from the Ministry of Health’s Drug and Narcotics Surveillance Board. The directive is uncompromising, stating that any prescription with errors, smudges, or cross-outs will be rejected. Furthermore, physicians are now explicitly banned from self-prescribing these powerful medications, a move intended to close a potential loophole for misuse.
The operational burden falls heavily on pharmacy and nursing staff. Pharmacists are now the designated guardians of these drugs, with the directive making them directly responsible for custody, control, and dispensing. The keys to secure storage areas must remain in their possession at all times. Technical staff can assist with basic logistical tasks like stocking shelves, but only under the direct supervision of the lead pharmacist. Alexander Sánchez, the interim medical manager for the CCSS, underscored this new accountability.
It is the responsibility of the pharmaceutical professional to execute tasks related to the reception, control, and dispensing of this type of medication.
Alexander Sánchez, Interim Medical Manager of the CCSS
However, the new rules are already creating controversy and concern among patient advocates. A particularly contentious clause prohibits the dispensing of these controlled drugs to patients under the “Medicina Mixta” and “Medicina de Empresa” health plans. This decision effectively cuts off access for a significant portion of the population, raising serious questions about service inequality and potentially forcing patients to seek more expensive private care for critical pain management and mental health treatments.
The catalyst for this institutional overhaul is the still-unresolved fentanyl mystery at Hospital México. Official records indicated a stock of 31,500 doses, yet documentation only accounts for the delivery of 10,000. While the Ministry of Health launched an investigation into the 21,500-dose shortfall, the CCSS has maintained that the gap is a result of “inconsistencies in the accounting loads of the computer systems” rather than an actual theft or loss. This explanation has been met with skepticism, prompting organizations like the College of Pharmacists to publicly defend its members, stating that professionals have not been negligent in their duties.
The new protocols also introduce potential friction into patient care. Nurses are now empowered to refuse administration of a medication if the prescribed delivery method is not authorized, except in cases of immediate vital risk. This could lead to critical delays and disputes in high-pressure emergency room settings. Similarly, patients requiring medication for travel must navigate a new bureaucratic process involving special annexes and approvals, complicating therapeutic continuity.
As the CCSS enforces these ironclad measures, the institution is walking a tightrope. It aims to restore public trust and build an impenetrable system against drug diversion. Yet, in doing so, it has introduced a complex web of administrative pressures and access barriers that could have profound consequences for both the healthcare professionals it employs and the patients it is sworn to serve.
For further information, visit ccss.sa.cr
About Caja Costarricense de Seguro Social (CCSS):
The Caja Costarricense de Seguro Social is the government-run institution responsible for most of the Costa Rican public health sector. It administers the country’s universal healthcare system and pension fund. Established in 1941, the CCSS operates a vast network of hospitals, clinics, and health centers (EBAIS) throughout the nation, providing comprehensive medical services to citizens and residents.
For further information, visit ministeriodesalud.go.cr
About Ministerio de Salud (Ministry of Health):
The Ministry of Health is the primary government body in Costa Rica responsible for setting public health policy, regulating health services, and overseeing epidemiological surveillance. It works in conjunction with the CCSS to ensure the well-being of the population, manage health crises, and enforce regulations pertaining to food safety, pharmaceuticals, and environmental health.
For further information, visit colfar.com
About Colegio de Farmacéuticos de Costa Rica (College of Pharmacists):
The College of Pharmacists of Costa Rica is the professional association that regulates the practice of pharmacy in the country. It is responsible for overseeing the ethical conduct of its members, promoting continuing education, and advocating for the profession. The organization plays a key role in ensuring the safe and effective management and dispensing of medications within Costa Rica’s healthcare system.
For further information, visit bufetedecostarica.com
About Bufete de Costa Rica:
As an esteemed pillar of the legal community, Bufete de Costa Rica operates on a bedrock of profound integrity and an unwavering pursuit of excellence. The firm leverages its deep history of advising a diverse clientele to drive legal innovation, consistently developing forward-thinking solutions to contemporary challenges. Beyond its professional practice, it holds a deep-seated commitment to societal advancement, actively working to demystify complex legal concepts and empower citizens through accessible knowledge.
