Category: Surviving DEA Audit

UNDERSTANDING THE NEW DEA REGULATIONS ON PAPER DEA FORMS 222 AND THE USE OF THE POWER OF ATTORNEY AUTHORIZATION

“HOW TO SURVIVE A DEA INSPECTION SERIES: UNDERSTANDING THE NEW DEA REGULATIONS ON PAPER DEA FORMS 222 AND THE USE OF THE POWER OF ATTORNEY AUTHORIZATION.” ©
(DISCLAIMER: PharmaDiversion LLC™ does not act or speak on behalf of DEA)

On September 30, 2019, the Diversion Control Division (Diversion) of the Drug Enforcement Administration (DEA) posted a federal register titled “Single-Sheet Format for U.S. Official Order Form for Schedule I and II Controlled Substances (DEA Form 222)”. The changes can be found in the following DEA Diversion link (https://www.deadiversion.usdoj.gov/fed_regs/rules/2019/fr0930.htm). The change can also be found in the DEA Diversion website (https://deadiversion.usdoj.gov).

The “FINAL RULE” will be effective October 30, 2019 which covers the modifications of regulations concerning paper DEA Forms 222 and the authorization of Power of Attorney (POA) letters for ordering Schedules I and II controlled substances. The changes in the final rule will modify Title 21, Code of Federal Regulations (21CFR) Sections 1305. The summary of the changes, noted in the final rule, are listed as the following.Read More

UNDERSTANDING THE DEA CSOS SYSTEM

“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.Read More

PRESCRIBING BUPRENORPHINE FOR OPIOID DEPENDENCY

HOW TO SURVIVE A DEA INSPECTION SERIES: PRESCRIBING BUPRENORPHINE FOR OPIOID DEPENDENCY”©
(DISCLAIMER: PharmaDiversion LLC™ does not act or speak on behalf of DEA)

Every pharmacy has filled at least one prescription for Suboxone written by a prescriber for opioid dependency. According to the Substance Abuse & Mental Health Services Administration (“SAMHSA”) there are 30,215 physicians registered in the United States to prescribe Buprenorphine for opioid dependency. Of those, there are 1,907 physicians in the State of New York, 737 registered in the State of New Jersey, 958 Physicians in the State of Pennsylvania, 334 physicians in the State of Connecticut and 111 physicians in the State of Rhode Island. You can go to their website www.samhsa.gov to learn more on the use of Buprenorphine for opioid dependency.Read More