Which of the following statements is true regarding mandatory patient counseling?
a. only an offer of counseling is required, for both new and refill scripts
b. only an offer of counseling is required for new prescriptions
c. actual counseling is required for both refill and new scripts
d. actual counseling is required for new scripts and an offer to counsel for refills
e. there is no mandate requiring either an offer of counseling or actual counseling