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Ordering Certain Controlled Substances through Form 222

DEA registrants are required to use form 222 to order some of the scheduled drugs. Following is a look at how to use the form along with other tips for DEA registrants to comply with the regulations.

The Drug Enforcement Administration (DEA) has a complete system and processes in place to regulate the controlled substances in the United States. The varied tools includes a series of forms for everything from registration and renewal of registration to ordering, import/export declarations, quota applications, theft/loss reporting and more.

DEA form 222 is to be used for ordering Schedule I or II (C-I or C-II) drugs from a pharmacy/supplier. Filling the form is simple and straightforward:

  • Provide the name and address at the top which should correspond with the details on the DEA certificate.
  • Provide the name, size, and quantity of controlled substance(s) required. The pharmacy will enter the National Drug Code.
  • Enter last line completed.
  • At the bottom, the DEA Registrant has to date and sign the form.

Earlier, this form used to be in triplicate with carbon paper. The registrant had to retain the blue purchaser's copy (bottom one) for the inventory records while submitting the other two to the pharmacy. The supplier will keep the original form for its records while mailing the third copy of the executed forms to the local DEA field office.

In October 2019, the DEA amended the regulation to shift to a single-sheet format which has to be given to the pharmacy. The purchaser can keep an electronic copy of the form at the registered location while the supplier no longer has to mail a copy to the field office. This move has eased recordkeeping requirements for DEA registrants while reducing the cost burden for the suppliers.
 

Other Uses


The same form can also be used to transfer Schedule II substances between laboratories. The receiving laboratory fills the form to ‘order’ the drugs from the other laboratory which becomes the ‘supplier’. Generally speaking, it is advisable to avoid transferring scheduled drugs between labs as it can be deemed as shuffling of paperwork to cover diversion.

Precautions


DEA form 222 is considered akin to a prescription pad and should be handled with due care. The DEA registrants are responsible for securing the forms obtained from the DEA office and retaining both the executed and unexecuted ones. They should make a list of the unique form numbers and record the date when each is used. They should never ever sign the form before it has been completed.

Apart from this, the DEA has a string of requirements to regulate registrants that deal with controlled substances. Complying with the varied laws and regulations while keeping a watch for thefts, diversions and other anomalies can become a millstone for many of the registrants. Professional service providers – like the Titan Group – can help ease the burden by ensuring that the registrant’s facility stays within the parameters of the law and meets all the requirements.
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