I A C P HOW TO SURVIVE A DEA INSPECTION SERIES: CSOS & DEA FORMS 222 By Carlos M. Aquino, Compliance Consultant and Founder of PharmaDiversion, LLC Every day I get calls from pharmacists asking about the Drug Enforcement Administrations’s (DEA) regulations pertaining to the ordering of Schedule II drugs through the DEA Controlled Substance Ordering System (CSOS) system. Understanding those regulations and following the proper procedure for completion, documentation, and recordkeeping will make any on-site DEA inspection run smoothly. A pharmacy must maintain copies of all executed, canceled and voided DEA order forms in either the paper version or the electronic format through the DEA CSOS system. If you are lucky enough to have the DEA come into your pharmacy, they have the authority to ask the pharmacy to provide two years of order form records required to be maintained as noted in the DEA regulations. If you order Schedule II controlled substances through the DEA CSOS system, the process will require four steps in order to complete any transaction. The first step is for the pharmacist to place the order. The system requires everyone ordering to have their own password. You cannot share your password. Sharing 14 I A C P C U S T O M Rx C O N N E C T I O N I A C P R X . O R G
Custom Rx Connection August 2012
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