HOW TO SURVIVE A DEA INSPECTION SERIES: CSOS & DEA FORMS 222
Every day I get calls from pharmacists asking for the DEA regulations pertaining to the ordering of Schedule II drugs through the DEA CSOS system. A pharmacy has to maintain a copy of all executed DEA Forms 222 whether it was done on a paper DEA 222 or electronically done through the DEA CSOS system. If you are lucky enough to have DEA come into your pharmacy, the pharmacy will need to provide a copy of an executed DEA 222 and DEA has the right to ask the pharmacy to provide 2 years of records which you are required to maintain by DEA regulations.
If you order from a supplier any Schedule II through the DEA CSOS system, it requires 4 steps in order to complete any transaction. The 1st step is for the pharmacist to place an order. The system requires everyone ordering to have their own LOGON/ PASSWORD. You cannot share a password. It will cost you $10,000 per transaction in a DEA civil action and the expenses for an attorney to represent you will exceed $25,000 for services. Each person other than the registrant is required to have an executed Power of Attorney signed by both the registrant and the person being granted permission to order from the DEA CSOS system. The signed form must be maintained for inspection.
The 2nd and 3rd step is left to the supplier which will acknowledge your order and will confirm the drugs quantities and date shipped to the pharmacy.
The 4th step is for the pharmacy to confirm the quantities received and the date received. You must do it on the date that you received the plastic tote from the supplier. The steps for this action are very simple. When you receive a tote verify the contents with the invoice that is enclosed in the tote. Once you documented what you received, go to the CSOS screen and confirm each item that you received in the tote that day. Print out a copy of the DEA 222 that you confirmed with CSOS and staple it to the invoice. File your DEA 222s on a monthly basis. Therefore, when you get the magic moment to meet with DEA and they ask you for your executed DEA Forms 222 you will be prepared to provide them immediately. Make sure you get a DEA Form 12 which is a DEA receipt if they take your original forms. If you follow this guideline you should never have a problem with DEA as long as the person ordering has a CSOS LOGON/ PASSWORD and you maintained the records.
This information is available on the DEA website www.deadiversion.usdoj.gov or contacts an association board member.