When it comes to controlled substances, veterinary practitioners need to follow the most rigid rules. Compare the federal state regulations, pharmacy board and veterinary boards-controlled substance regulations or veterinary DEA regulation. You must follow the one that applies to your practice but meeting the stricter requirement will keep you in the safe book of the regulators.
Home veterinarians must have a DEA license if dealing and dispensing controlled substances. They can have one registration if they only prescribe drugs in one state or different locations within the state. But if they store and dispense controlled substances in different locations within one state, they must have different DEA licenses. If they practice in different states, then they must have multiple DEA licenses along with state licenses, name of the animal and owner.
Veterinary DEA regulations
The license allows DEA veterinarians to transport, administer, and dispense controlled substances to unregistered locations. These could be remote areas like pastures, stables etc. It is important that while they carry the controlled substances, they must comply with the DEA regulations and the state and federal rules. Mobile practitioners should register their address to the operation base from where they conduct the services. This will enable them to prescribe controlled substances from any location, but the storage of the drug should be at the base location or other registered location. When it comes to veterinary relief workers, they usually do not store any controlled substances complying with their license. Those carrying mobile stock should only carry enough for a basic operation, the excessive supply should be confined to the main location. The security measurements of the lockbox that would store the control substance should comply with the highest security and should not be left out of sight. The schedule II control substance drugs like morphine, Demerol, oxymorphone, fentanyl patches, require suppliers to have an accurate DEA form 222 to sell these drugs.
Controlling opioid abuse
In the veterinary practice, the abuse of opioids has been reported. A survey conducted in 2014 revealed that 13 per cent of veterinarians knew that the pet owners had deliberately made an animal ill to obtain the opioid medications. A quantitative number, almost 44%, were not ignorant of the misuse of opioid medications being given away to clients. The internal staff too were misusing the opioid medications. This makes the laws on veterinarians more stringent than any other prescribers and controlled substance dispensers. When a controlled substance is prescribed, state and federal law and DEA require that the prescription includes the information along with the name of the patent, address, and the date of the issued prescription. Prescription issued by veterinarians must not only include this information but information on the animals’ species, the name of the owner and the address along with the controlled substance prescribed.
The use of opioids has been largely restricted for humans since 2018, veterinarians prefer this control substance in addressing pain and using is it as optimal anesthesia on pets. Critical cases requiring surgical intervention can be managed better with the opioid. But owing to the restrictions on opioids, veterinarians are being pushed to choose non-opioid alternatives to control pain.
With a growing crisis in 14 states including Washington DC, the PDMP state prescription drug monitoring program encourages veterinarians to check the pet owners pharmaceutical purchase history before the medicines are prescribed for the pet. This extra measure will help in controlling the abuse to some extent. The same practice was carried out on humans and according to a CDC report, there was a drop of 75% in medical drug opioids abuse. Some states like New Jersey have set a limit on the purchase of drug quantities. There is a five-day strap on initial opioid prescription for both animals and humans. Stringent bookkeeping in hospital and maintaining records of bottles unopened, open bottles, number of pills dispensed.
Maintaining a veterinary controlled drug log
Veterinary clinics and hospitals must have a controlled substance program or veterinary controlled drug log. This should include the requirements, the substance used in the federal and state registers. This system will keep them prepared for audits and reviews whenever they take place. Those veterinarians who have faced no inspections to date are being scrutinized by the DEA. Controlled drug programs ask questions like the clients’ name, patients name, where was the controlled substance dispensed from- the clinic or the hospital supply. What is the storing format of the controlled substance? Are they kept in secure cabinets? They look for written inventories of signed and dated documents within the last two years of all controlled substances. Purchase records for all schedule II-controlled substances are checked with receipt. This will raise an alert of a missing controlled substance. When the shipment for controlled substances is received the written copy should be stamped with the quantity and the date on which the drug has been received and retained. Completed forms should be maintained and should not be mixed with the accounting papers and kept separately. This applies to all controlled substances. Maintaining a copy of the invoice will help resolve discrepancies. Keeping these records well maintained is a must as during audits if there are any loose strings the consequences can be significant and may put the hospital at grave risk.
Good practices followed by veterinarians will keep them safe and enable them to provide continuous service. They should always keep the following documents in a file for sudden inspections. They should have their current DVM (Doctor of Veterinary Medicine) license. They should have their updated DEA (Drug Enforcement Agency) veterinary license, The current DEA state license for the state which requires one, and professional liability insurance.
Conclusion
Being in touch with the TITAN Group will help veterinary professionals follow the practices defined by DEA. Mitigating violations with strong corrective practice have benefitted practitioners from New York to Hawaii. Clients have been able to save fines if up to $90K that would easily have escalated to $15,040 per violation. Better practices have also resolved the issue of indefinite shutdown imposed by the DEA for malpractice. The TITAN Group helps you preserve your peace of mind knowing that you are adhering to compliance and working by the books.
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