HOW TO SURVIVE A DEA AUDIT AND INSPECTION SERIES: YOUR PHARMACY NEEDS TO KEEP AN ACCOUNTABILITY FOR YOUR CONTROLLED SUBSTANCES. ©
DISCLAIMER: PharmaDiversion LLC™ does not act or speak on behalf of DEA
I am seating at my home office in a quarantine state doing three pharmacy employee theft computation charts to evaluate what controlled substance the pharmacy technician or the staff pharmacist stole. I cannot wait to travel to New York, New Jersey, or Pennsylvania to assist our clients with their issues relating to their theft of controlled substances by someone who the registrant or pharmacy manager believe was a reliable employee.
The registrant (owner) discovers that the trusted employee stole 85,000 dosages of Oxycodone 30mg tablets over a year period. Now you are wondering, if you will still have a pharmacy after notifying the Drug Enforcement Administration (DEA)?
Let us be honest. You were so busy, and you could not keep a perpetual inventory on your controlled substances. Let me tell you, this in the eyes of DEA is not an excuse. If you operated a chicken coup, would you trust the fox to keep their eyes on your chickens? Why would you trust anyone to keep their eyes on your pharmacy controlled substances?
In the end, an employee who knows you do not keep a perpetual inventory will steal your controlled substances. Why? Because Oxycodone 30mg tablets can bring $30 per tablet on the illicit market. How would you feel if you found your employee stole 85,000 Oxycodone 30mg tablet? This happened to a pharmacist in New York.
It is important that your pharmacy take numerous steps to prevent an internal theft or a significant shortage of controlled substances. The following recommendations can prevent the theft or significant loss by the pharmacy.
- Your pharmacy should maintain a perpetual inventory of all Schedule II controlled substances and selected Schedules III through V controlled substances.
- Schedule II controlled substances should be stored in a locked cabinet or safe and access should only be done by the registrant and staff pharmacists.
- Your pharmacy should verify the quantities whenever a Schedule II or any of the selected Schedules III through V controlled substance are dispensed to determine that the actual quantities on-hand match the perpetual inventory.
- Your pharmacy should audit all Schedule II and selected Schedules III through V controlled substances on a quarterly basis.
- Your pharmacy should only permit a few pharmacy staff members to place an order for any controlled substance. When the orders are received, a different pharmacy staff member should verify the quantity that are received from controlled substance suppliers.
- If you share your CSOS password, DEA will revoke your DEA CSOS software used to purchase Schedule II controlled substances.
- Your pharmacy needs to implement a policy that the NDC code used for a prescription is the NDC code noted in the prescription software.
- Your pharmacy should reduce the number of their cash prescriptions to less than 5% and all opioid prescriptions should be paid with insurance only.
- Conduct criminal history for all pharmacy staff every three years. You cannot hire someone with a felony conviction for controlled substances. Think about implementing drug testing.
As I noted in this article, as the registrant or the supervising pharmacist or manager, you are responsible for all controlled substances in your pharmacy. My question to you is quite simple. Do not trust the fox?
Carlos M. Aquino