Courtney
Education Specialist
When it comes to DEA audits, there’s one thing every veterinary practice dreads — a DEA inspector at the door when least expected. The best way to handle it is to stay ahead by keeping your controlled substance records and documents audit-ready every single day.
Courtney and Cass, VetSnap compliance experts, explain how to navigate an audit with confidence in the latest episode of Compliance Bites.
This conversation is packed with practical tips and real-life examples of how to handle controlled substances with ease.
Courtney and Cass are also veterinary practitioners and they know all ins-and-outs of how veterinary clinics deal with controlled substances. They mention common mistakes, ways to fix them, and red flags for a DEA inspector.
Here are some key points and tips from their talk:
- Do an inventory count and know your numbers
- Check whether you included all necessary information in log entries
- It’s OK to fix errors and do corrections – it shows you’re proactive with your records
- Make sure all essential documents are ready for the inspection
Learn more from the video above!
We’ve also prepared a small cheat sheet below to help you keep your controlled substance logs audit-ready at all times:
5 Essential Steps to DEA Compliance
Step 0: Begin with an Inventory Physical Count
Before anything else, you need to conduct a hands-on count of all your scheduled drugs in safes, lockboxes, and other storage areas.
A physical inventory count is required every 2 years (biennial count) by federal law. It is outlined in the eCFR (Chapter II, Part 1304.11). Yet, VetSnap experts recommend doing it much more frequently — monthly, weekly, or as soon as possible.
Why? Because you’d better know your current inventory levels before the inspector’s visit. Every count should be well-documented and signed. You cannot proceed to reconciliation until you verify what you have on hand.
Step 1: Check Whether All Your Numbers Match
Once you complete your physical count, it’s time to start reconciliation. Compare what you actually have on hand with your controlled substances logs. This is the key step that will give you confidence in your controlled substances logs. Doing this daily will turn it into your habit and help ensure accurate logs.
Step 2: Address All the Discrepancies and Missing Data
If you spot logging mistakes (e.g., math errors) or missing data (e.g., blank address), don’t ignore or try to cover them up. Recognize an error and fix it properly without erasing. Avoid using correction fluid or white-out.
Show the DEA auditor that you’re proactive with your logs — that you monitor them and make corrections when needed. When logging, Courtney and Cass recommend you to:
- Add comments
- Date everything
- Update logs without deleting entries
- Ask witnesses to confirm corrections with their signatures.
Step 3: Update Your Authorized User List
Regularly check that your Authorized User List is up-to-date. It’s crucial to know who can access your controlled substances and control access through clearly-defined permissions.
So, any time there’s a staff change in your practice, it’s better to update your Authorized User List, POAs, as well as physical access permissions.
Step 4: Review All the Documents (Licenses and Forms)
Have your documents, such as licenses, DEA forms (222s, 41s, 106s, etc.), in place and readily accessible. Pay close attention to your DEA forms, for example, especially Form 41 if you destroy controlled substances in house. Don’t forget to document not only how many controlled substances you’ve ordered, but also how many you’ve received using Form 222.
Also make sure your registration and license are renewed and up to date to be able to handle controlled drugs.
Step 5: Maintain Clear Organization of Binders and Documents
Keep all documents and logs clearly organized as it helps to easily retrieve any entry you need. Plus, the DEA inspector can spot the slightest mess in your records, simply by asking you to provide information on a specific scheduled drug. So, if you bring them a box of mixed papers, it will complicate the DEA inspection.
It will show that organization of records is poor, prompting an auditor to dig deeper. Make it easy for the DEA auditor by providing them with the data they request.
To Wrap Up
Paper-based recordkeeping is a tedious, error-prone, and time-consuming job.
VetSnap is here to help you organize records, keep them all in one place and accessible 24/7.
Feel free to contact us and book a meeting with our experts! By the way, many of them are former veterinary professionals who went through the same logging troubles as you might have now.