Staying DEA compliant with secure medication storage
Drug diversion is a mounting challenge in veterinary medicine, especially as Drug Enforcement Administration (DEA) compliance becomes more critical to your daily operations. But practices and veterinary hospitals aren’t without options. Existing technology is often incredibly helpful for maintaining DEA compliance, supporting efficiency, and helping your staff provide the best animal health possible. Taking advantage of this technology starts with understanding drug security, how important compliance is, and how digital workflow solutions support your handling of controlled substances and high-value pharmaceuticals.
Drug security basics
Veterinary hospitals are responsible for understanding and applying the basics of drug security. Here’s a quick overview.
Federal, state, and local governments regulate controlled substances. The U.S. Drug Enforcement Administration (DEA) is primarily responsible for enforcing the Controlled Substances Act (CSA).
2. Drug schedules
Under the CSA, drugs, ranging from valium to codeine, fall under five schedules, ranked by decreasing potential for abuse. The clinic or hospital as well as drug vendors must have a DEA license on file before you can purchase, store, or dispense controlled substances.
The DEA requires that veterinary practices keep usage logs for all controlled substances. It also requires that practices store Schedule II logs separately from Schedule III, Schedule IV, and Schedule V logs. Schedule I narcotics are those that have no currently accepted medical use and wouldn’t be found in a medical facility.
Why DEA compliance matters
Efficiency in managing controlled substances can drain the resources and time of any veterinary practice or hospital — and the stakes are often high. In cases of blatant mismanagement, a veterinarian can get into trouble with not just veterinary boards, but also the DEA. DEA inspection can involve visits from armed agents who enter the hospital and immediately examine the CS log.
According to Matt Zumbro, Technology and Solution Strategist at MWI Animal Health, “One of the DEA requirements is that veterinarians have to be highly specific in tracking. They have to document patient, day, time dispensed by whom within the hospital, how much was given to what patient, and more.”
Veterinarians are also responsible for maintaining the logbook and making sure it matches what’s in their inventory. The DEA expects that the veterinarian on the license knows where a drug is at all times and whether it’s been dispensed or destroyed.
Improve compliance through technology
But as diversion challenges have become more complex, technology has helped veterinary practices keep up.
Automated dispensing machines (ADMs) can improve security, increase efficiency, cut back on errors, and even capture lost billing opportunities. Still, they don’t necessarily translate to DEA compliance. Drugs can still be diverted by unscrupulous staff and human error can still be a challenge.
Robust compliance systems, on the other hand, can detect these issues. Zumbro continues, “Sometimes it’s not even about an error and instead people just being people. Anytime you have manual processes in place, things can get missed or communication can even break down when handwriting is illegible. For some people, it’s not a problem. For others, people can’t read what they’ve documented when it’s time to reconcile.”
An ideal digital compliance solution will eliminate the risk of human error and variability, syncing your logbook with your practice management system (PMS) so that scheduling and inventory management are fluidly connected.
Dual-factor authentication is particularly powerful for maintaining your drugdispensing system’s security. Also known as 2FA, “two-step,” and “verification,” it relies on two elements to authenticate a user: something you know (like a PIN code), something a user has (like a smartphone or hardware token), or something about a user (like a fingerprint). Dual-factor authentication uses two of these three options to verify a user is who they say they are and to grant them the appropriate access.
The most effective systems will require dual-factor authentication for individual staff (such as a PIN code and/or fingerprint). Ideally, they will also have to choose a patient before the safe opens. Sophisticated systems often feature a kiosk that allows staff to scan what they’re removing, indicate the amount, and automatically log the entry.
These features can result in a huge step up to better drug security, especially for veterinary practices that share passwords or just leave a key in the safe all day.
Benefits of the digitized logbook
Another highlight of modern drug-dispensing technology is the digitized logbook, a feature that automatically records drug access. Zumbro explains how things work in many analog practices today.
“Right now there are a lot of different ways that hospitals are keeping their controlled substance logbook. Most of them do it manually, so it’s essentially a three-ring binder with paper sheets that have multiple spaces for entries. And as staff members come to a drug safe where items are stored, they make a manual entry in the log to document what they’ve taken and who they’ve given it to.”
The benefit of a digitized logbook is that in a situation in which staff get distracted and grab the wrong drug or make another mistake, it can catch it during reconciliation. The digitized logbook provides a date and electronic time stamp of who was in the safe and when. This allows you to converse with that staff member about whose drug it was and how they used it. It also helps alleviate the risks of running an office on a “log it if you can” or “when you have time” culture — one that is subject to errors in human memory, simple mistakes, or illegible handwriting. This approach even contributes to noncompliance and can potentially lead to the loss of the doctor’s or facility’s DEA license.
By examining and comparing digital workflow solutions, veterinary practices are taking an important step toward bringing their patients a safer experience, freeing their staff to spend more time on patient care, and ensuring the sustainability and compliance of their practice.