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Security
Equally as important as recordkeeping and inventory are
your controlled substance security measures. When it
comes to security, most individuals automatically think of
alarms, cameras, and access control, etc. (in fact, many
of our veterinarian clients haven't thought of this at all).
Controlled substance security measures are actually
two-fold:
1. Physical security. First, and most obvious is your
facility's physical security. Does your facility have an
alarm system? Are surveillance cameras installed
throughout the building, and are they properly
positioned to monitor areas where controlled
substances are stored, accessed, and disposed of? Are
your controlled substances stored in a DEA-compliant
4
locked storage unit? If so, how many individuals have
keys and/or access codes?
2. Personnel security. Less obvious when it comes to
controlled substance security are the measures you
should be taking regarding the individuals that work
for you. How well do you know your employees, really?
If you aren't conducting routine background checks on
your employees, there's a good chance you may not
know the individuals working for you as well as you
think you do. Many of the headlines regarding veterinary
drug diversion that have popped up throughout the
industry recently could have been averted if employees
were properly vetted from the start.
Once an employee has been vetted and qualified to work
with controlled substances, they still also need to be
properly authorized to do so by the DEA registrant. Make
sure that you have Authorized User forms in place that
have been executed by the DEA registrant and Authorized
User on file and stored onsite in a secure location. Also
remember that to comply with DEA requirements, all
Authorized Users must also complete an employee
screening on a yearly basis (21 CFR 1301.90).
2
Due diligence begins with the hiring process. Implement a
company-wide policy that mandates background checks
for all new and any existing employees, along with random
drug testing, and annual employee screening statements.
By implementing a company-wide policy, you create a
standard of compliance that clearly defines expectations
and will also protect you from potential claims for
discrimination.
Compliance checklist
If you've been procrastinating on controlled substance
compliance because its overwhelming or seems too hard,
not to fear. Hit the "easy" button and take control of your
DEA compliance today by starting with the following:
• Conduct a biennial inventory.
• Resolve any discrepancies identified.
• Implement a regular reconciliation schedule.
• Review security measures.
• Know your employees.
• Have a backup plan.
Need help? We're on your side.
Still not sure where to start? The TITAN Group is here to
assist. Depending on your unique circumstances, we offer
virtual and on-site services to evaluate and remediate
issues/discrepancies so that so that if the DEA does show
up at your door, you are prepared.
References:
1. https://www.deadiversion.usdoj.gov/pubs/manuals/narcotic/part6/index.html
2. https://www.deadiversion.usdoj.gov/21cfr/cfr/1301/1301_90.htm
3. https://titangroupdea.com/addiction/dea-issues-new-marching-orders-in-the-war-
against-opioid-addiction
4. https://www.deadiversion.usdoj.gov/pubs/manuals/sec/sec_req.htm
DEA compliance made easy
