Home / Educational / What are the top 6 reasons for failing a DEA audit? Find out and stay one step ahead!
Courtney
Sales & Educational Specialist
Failing a Drug Enforcement Administration (DEA) audit can be a significant concern for hospitals due to the strict regulations governing the handling of controlled substances. Here are the top reasons hospitals can fail such an audit:
Reason to fail DEA audit
How VetSnap Can help?
Inaccurate or incomplete records
VetSnap users report significantly more efficient record keeping, and are better prepared to respond to DEA audits
The DEA requires accurate, complete, and readily retrievable records for all transactions involving controlled substances. This includes prescriptions, order and receive, usage, waste, and real time inventory balances. Failure to maintain detailed records or discrepancies between actual inventory and what’s recorded can lead to audit failures. Transactions need to be accountable and tracked to individual signatures, and changes and modifications need to be clearly documented. DO NOT FORGET that you need to do a Biennial Inventory Count.
VetSnap Users report increased accuracy of physical counts and decreased time spent doing record keeping compared to paper logs. With our DEA day by day audit report, you can provide exactly what the DEA needs in a format that they are familiar with. Also, part of the benefit of VetSnap is that you can quickly create DEA compliant physical counts for Biennial Reports.
Failure to track and account for inventory balances by containers
VetSnap provides best-in-class tracking for the entire life cycle of the container
This issue is somewhat unique to the veterinary world. In the human healthcare industry, oftentimes a container of a controlled substance is assigned to one patient, whether or not that container is fully used up or not during the treatment. However, as we all know in the veterinary world, our containers of drugs can be shared across multiple patients at a time. This makes the accounting for containers much more important to do correctly, because rather than being able to point to one instance, veterinarians must be able to go back and show exactly how much was used up for which patients, for any given container.
VetSnap’s logging process is easy and familiar to hospitals that follow best practices around controlled drug logging, which start with tracking your container right when it comes into your hospital, and follows that container through its entire lifecycle of when it was opened, used, wasted, finished, and reconciled to 0 balance. We provide an easy and automated way to assign containers to logs, and calculate container balances and report on container balances using our DEA day by day audit report, which is THE preferred format for doing drug audits by DEA agents these days.
Inadequate security measures
VetSnap integrated safes and lockers provide a holistic, affordable, and flexible solution to managing physical access to controlled drugs
Hospitals must implement effective controls and security measures to prevent theft or loss of controlled substances. This includes secure storage (e.g., safes or locked cabinets for Schedule I and II drugs), proper employee access controls, and surveillance systems. Inadequate security measures or evidence of diversion without prompt investigation and reporting can result in violations. See: § 1301.75 Physical security controls for practitioners, part (b) Controlled substances listed in Schedules II, III, IV, and V shall be stored in a securely locked, substantially constructed cabinet.
VetSnap Integrated Lockers is now open for enrollment. Compliance is a journey, and we can all use help along the way. Deploying an affordable solution like VetSnap Integrated Lockers will help your hospital better comply with logging procedures to maintain compliance, without adding overhead in staying compliant. Our lockers are integrated with your DEA controlled logbook, creating a seamless record that shows any auditors that you take compliance seriously.
Improper disposal of controlled substances
VetSnap makes waste tracking and reconciliation simple and pain free
The DEA has specific regulations for the disposal of expired, damaged, or no longer needed controlled substances. Hospitals must follow these guidelines to ensure that such substances are not retrievable or reusable. Failure to comply with proper disposal procedures can lead to audit failures.
We make waste documentation easier than ever to create. You can waste a container or a specific amount associated with a patient, all with signatures documenting and witnessing the process for review. Furthermore, if you deploy VetSnap Integrated Lockers, you can set aside a dedicated safe for finished containers (which will still contain material amounts of controlled drugs), and keep track of where your finished and wasted containers are held before reverse disposal.
Lack of employee training and adherence
VetSnap follows best-in-class processes that encourage better record keeping
Hospitals are required to train employees who handle controlled substances in compliance with DEA regulations. This training should cover proper handling, documentation, security, and disposal of controlled substances. A lack of training or failure to maintain training records can be a red flag during an audit.
Training and Process go hand in hand. It is important to provide training, and with VetSnap, logging processes are easier than ever to follow. We put safeguards in place for your hospital based on your SOP, including double confirmation, double signatures, and permissions based access of your logbook and physical safes that allow admins to train their staff and grant access to specific people based on their needs and capabilities.
Non-compliance with Prescription Regulations
VetSnap provides a simple state reporting solution for Prescription Monitoring Programs in mandatory states
For hospitals that dispense controlled substances, compliance with prescription regulations is crucial. This includes ensuring prescriptions are for a legitimate medical purpose and complying with state regulations around prescription monitoring and reporting. Non-compliance with prescription protocols can lead to significant issues during an audit.
VetSnap PMP reporting is an affordable and easy to use add-on that allows practices in mandatory reporting states to submit PMP ready reporting based on information that is 90% already available in the controlled log book. Save time, and reduce manual entry error, and reduce the frustration of entering in dispense reports patient by patient in your state’s reporting portal with VetSnap PMP Reporting.
Proactively addressing these areas can help hospitals avoid the pitfalls of a DEA audit and ensure compliance with federal regulations governing controlled substances. Regular internal audits and compliance checks can also be beneficial in identifying and rectifying potential issues before they become problematic during an official DEA audit.