Session 4 Law and Ethics Part 1 Flashcards
DEA 1973 function
Main function to combat abuse of controlled substances.
Controlled substance act
Defines schedule of the drug based on likelihood of abuse
Handling of individual schedules of drugs are handled and enforced by
The DEA
Prescribe
Write a prescription to be dispensed by a pharmacy
Dispense
Includes all steps necessary to translate a rx into an individualized medication supply.
Administer
Give drug to patient according to label/instructions
State practice act allows non-vet staff to administer controlled drugs at the direction and under the supervision of the vet if:
They are agents/employees of the registered practitioner
They are performing the task in the usual course of business
They are acting under the direction of a licensed vet
They are under supervision of a licensed vet
Non vet staff are allowed to administer controlled drugs under which law
State practice acts
Direct supervision
Can mean simply that a licensed veterinarian is on premise
Relief veterinarians can administer controlled drugs if
They maintain a separate DEA registration.
This allows for compliance with the controlled substance act.
Supports contractor status to tax authorities
What needs to happen if there is a termination of DEA registration (registrant dies, stops practicing, no longer is licensed, etc)?
Notify DEA immediately
Turn in any unused drug forms
Contact DEA to determine how to best dispose of unused controlled substances left.
What schedule of drugs warrants a 222 form?
Schedule 2 drugs
What drug classes do not need a special form to order?
Schedules 3, 4, 5
What to do if 222 forms are missing?
Contact the DEA - give registrant information and serial numbers of missing forms - if numbers are not known ask how to best proceed
How do you use 222 forms
Copies 1&2 of the form are submitted to the supplier
Copy 3 of the form is retained by the registrant
Supplier retains copy 1 and sends copy 2 to the DEA
Once the drugs arrive to practice the date of receipt and qty of each drug needs to be recorded on copy 3 of the original 222 form
Must be stored separately from medical records
How do you lend scheduled drugs to another veterinarian?
For schedule 3,4,5 -
Transfer qty of drug to another registrant and obtain a receipt signed by the registered veterinarian who received the drug. Store the invoice in drug log. If receiving drugs keep the receipt showing drugs are not from a distributor.
Schedule 2 - use 222 forms
How do controlled drugs work in a new practice?
Upon acquisition an initial inventory must be taken
Practitioner transferring drugs must prepare an invoice of all drugs being delivered dated and signed by both themself and the receiver. The invoice must specify if count was done at close or beginning of day.
An exact count of scheduled 2 drugs is required
Every 2 years following the initial inventory date the registrant must take new counts and maintain those records for 2 years.
When can you estimate inventory counts of scheduled drugs?
For schedules 3,4,5 unless the container holds more than a qty of 1000.
How do you store controlled drugs?
Securely locked in a substantially constructed cabinet/safe
Drug stocks kept to a minimum
Access to storage should be restricted to only the absolute minimum amount of employees
Do all scheduled drugs need to be stored together?
No
Schedules 3,4,5 can be stored with non controlled drugs as long as still stored in a substantially constructed and securely locked cabinet.
What do you do if there is loss of theft of controlled drugs?
Registrants are required to notify the regional office of the DEA using a DEA form 106
Notify local police
What do you do for significant breakage or spillage of a controlled substance?
Use form 106 to notify the DEA.
May also want to notify local police
What is form 106 used for?
Informing DEA of Theft, loss, spillage or breakage of controlled drugs
Employee prohibition required - controlled drugs
A practice cannot employ someone who has had their DEA application revoked or denied if they will have access to controlled drugs while on duty
Employee responsibility to report
Employees are responsible to report drug diversions from any fellow employee. The info will be confidential.
Failure to report will be a determining factor in the feasibility of the employee continuing to work in a drug secure area