Controlled Substance Federal Policy
At United Veterinary Care, we know the significant role that veterinarians and staff members play in improving the safety of each other, our patients, and the community with regard to the Opioid crisis. We also understand the importance of being compliant with all of the Federal and State DEA regulations when it comes to Controlled Substances. Therefore, it is the responsibility of each United Veterinary Care Veterinarian to guide our team members in the importance of maintaining current, complete, and accurate controlled substance records according to all local, state, and federal controlled substance guidelines.
OBJECTIVE
The objective of United Veterinary Care’s Controlled Substances Policy (the “Policy”) is to ensure compliance with all local, state, and federal regulations governing the use of the Drug Enforcement Administration’s (DEA) Controlled Substance Regulations. In all cases, United Veterinary Care Veterinarians will follow the most stringent of regulations.
POLICY
United Veterinary Care requires that all individuals working with Controlled Substances comply with all local, state and federal regulations regarding the acquisition, storage, administration, dispensing, prescribing, recordkeeping, and disposal of the Controlled Substances. As noted above, in the event there is ever a conflict among regulations, United Veterinary Care will follow the most stringent of regulations.
RESPONSIBILITIES
All DVMs providing veterinary services at United Veterinary Care are required to have a current DVM license, a current DEA Certificate (proving current DEA registration), and a current State Controlled Substance license (where applicable) for the State(s) where they provide veterinary services. It is imperative that DVMs do not allow their DEA certificates to expire as most State Veterinary Boards are required to report expired licenses to the DEA. Each location of business is required to be registered pursuant to 21 CFR § 1301.12 and have at least one (1) licensed DVM who is currently registered with DEA as the location’s “Primary Registrant” and a minimum of one (1) authorized staff member responsible for compliance with applicable state and federal regulations. The DVM, who is the Primary Registrant, is responsible for managing the Controlled Substances in accordance with the requirements of the DEA’s Federal regulations (e.g., Title 21 CFR § 1300-1321, et seq.)and State regulations, including inventory, recordkeeping, and security provisions. The Primary Registrant shall maintain current knowledge of all DEA requirements.
The Primary Registrant is responsible for compliance with all Local, State and Federal Controlled Substance Rules and Regulations. This includes educating all United Veterinary Care Practitioners and staff members about Controlled Substance regulatory requirements, assisting as necessary during new hire implementation, providing ongoing training, and providing regular and ongoing oversight to ensure Controlled Substance compliance is current, complete, and accurate at all times.
OVERALL GOAL
The overall goal of United Veterinary Care’s Controlled Substance Policy is to show how the Controlled Substances are used within each practice’s closed system when ordering, receiving, securing, storing, recordkeeping, logging, administering, dispensing and/or prescribing Controlled Substances to the ultimate end user, (the pet and/or pet parent on behalf of the pet). At the beginning or end of each workday, the Primary Registrant and/or his/her authorized employee(s) will complete the daily reconciliation (aka daily inventory) of all Controlled Substances to assure the balances are current, complete, and accurate by writing the daily reconciled total of each substance in the Controlled Substance Administration and Dispensing Reconciliation Logs by Schedule. All Controlled Substances in each United Veterinary Care practice will be stored in a lockbox (or lockboxes) that are securely adhered to the floor or wall of each United Veterinary Care practice as described in this Policy. Compliance with this Policy is mandatory, and any non-compliance may result in disciplinary actions, up to and including immediate termination of employment and will result in reporting to all applicable authorities. The Chief of Operating shall review further and advise on necessary actions.