“HOW TO SURVIVE A DEA INSPECTION SERIES: UNDERSTANDING THE DEA CSOS SYSTEM” ©
(DISCLAIMER: PharmaDiversion LLC™ does not act or speak on behalf of DEA)
Every month an independent pharmacy supervising pharmacist or a pharmacy owner will contact us on applying for access to the DEA Controlled Substance Ordering System also know as CSOS. Generally, the application they submitted was incorrectly done. So, let me help you understand the system and application.
For a pharmacy to purchase Schedule II controlled substances, they are required by DEA regulations to use a paper DEA Form 222 or use the option of the CSOS system. Yes, I say option. If your CSOS account is suspended by DEA or the supplier, you will need to use the paper DEA Forms 222. We have seen many cases where a supplier has cancelled an account or that DEA suspended a CSOS account because of the late renewal of the pharmacy registration renewal.
For CSOS, there are three types of applications. They are the Form 251 for registrants, Form 252 for coordinators, and Form 253 to grant Power of Attorney (POA). Here is what you need to know.
CSOS DEA FORM 251 – This form is submitted by the pharmacy owner who wants to order Schedule II controlled substances for the pharmacy. We recommend that all owners apply for this category. Why, because if you give that responsibility to someone else as a Coordinator and that person leaves, the account will be closed by the DEA CSOS Unit. Therefore, you need to be the registrant and you can grant POA to other persons. With regards to the application and any renewals, we recommend you place your name as the person doing the initial or the renewal application. By doing this, the CSOS account will only be closed by you.
CSOS DEA Form 252 – This form is submitted by someone that the pharmacy owner delegates the authority of a Coordinator to purchase Schedule II controlled substances and to give POA to other persons. This form is signed by the owner who has claimed that they don’t want to have CSOS privileges. As the owner of the pharmacy, we want you to know that if the Coordinator leaves the pharmacy, you are responsible to contact the DEA CSOS Unit within 6 hours of the person leaving the pharmacy. This will automatically close your account and you will need to use the paper DEA Form 222. We don’t recommend you have a Coordinator. Period!
CSOS DEA FORM 253 – This form is used by the DEA CSOS registered owner to grant any individual POA to purchase Schedule II controlled substances. If you, the owner, submitted your DEA Form 251, you can grant and revoke POA to anyone. We recommend you go this route.
So, as the owner of a DEA registered independent retail pharmacy, we recommend you apply with DEA Form 251 and grant POA to others using DEA Form 253. We don’t recommend you use a Coordinator.
Carlos M. Aquino