Can you name several controlled drugs used in veterinary medicine? Maybe you are a veterinarian or a veterinary technician and you are well-versed in which drugs are controlled. That’s great! Maybe you are an IT guru or a practice acquisition lawyer and have no idea which drugs are considered controlled substances. That’s OK too!
As a veterinary pharmacist, I don’t need everyone I work with to know all about which drugs are controlled. However, when a piece of technology that is part of my controlled substance security or record-keeping breaks, I need my IT person to appreciate why I’m freaking out and then fix it. If the DEA shows up and starts writing citations, I need legal counsel to understand the significance. I could go on, but you get the idea.
Pills and a Warning Label
DEA compliance is preventive care for a veterinary practice. If an employee is diverting controlled substances, that causes issues that, when exposed, could erode the trust in the practice. Employee diversion often leads to large fines from DEA citations (over $15,000/citation), bad publicity, a poor-quality work environment, poor company culture, and compromised patient care. Veterinarians are well-versed in how to educate clients on the best preventive care plan for their pet, but often are less confident in their ability to practice preventive care for their DEA license.
DEA regulations are complex and annoyingly vague in some areas. Therefore, we must remember that the intent is sufficient controlled substance security and oversight. What is needed to accomplish this will vary from one practice to the next necessitating a practice-specific approach. However, the following three tips will get any practice heading in the right direction.
1: Have a comprehensive controlled substance policy/SOP that is known by all employees and reviewed yearly for necessary updates
The DEA regulations are minimum requirements for controlled substance security. Each license holder/practice is responsible for identifying potential opportunities for diversion in their setting. This means that controlled substance security will look different from one place to the next. That isn’t a bad thing, but your processes must be documented.
Create a controlled substance policy or SOP to describe how everything from controlled substance ordering to record-keeping to disposal are handled in your practice. Review and update this frequently, share with all new employees, audit to ensure actual practices are compliant with expected practices, and have it on hand if the DEA decides to come inspect.
2: Ensure the DEA license holder is periodically involved in controlled substance processes, such as during a monthly inventory count
The DEA license holder can delegate controlled substance management as they see fit. However, they can’t delegate the ultimate responsibility. When the DEA shows up, it’s the license holder that will be held responsible for what is or isn’t happening with the controlled substances under their license. Therefore, the license holder needs to be involved periodically to ensure they are comfortable with the checks and balances in place.
3: Have frequent checks to verify actual quantity on hand matches expected quantity
Controlled substance inventory is only required every other year at the federal level (states may require it more frequently). However, if you are only verifying the actual amount of controlled substances every other year, when you discover a discrepancy, it will be difficult to determine what happened. Therefore, frequent checks to ensure the amount on hand matches the amount indicated on the running inventory is important. I recommend doing these checks weekly, every other week, or monthly depending on volume of controlled drugs dispensed. These inventory verifications are a great place to incorporate the license holder as well.
Everyone in a veterinary practice is affected when controlled substance diversion comes to light. Therefore, everyone should be involved in ensuring the security of controlled substances. Non-diverting staff are the first line to identifying diversion, so it’s essential for a “see something, say something” culture to be the norm.
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