your logon and password information may cost you up to $10,000 per transaction in a DEA civil action, plus the expense for an attorney to represent you which may exceed $200,000 because DEA will take a civil action against your pharmacy registration. Each person ordering other than the registrant is required to have a signed Power of Attorney. It is signed by the registrant and the person being granted permission to place an order through the DEA CSOS system. The signed form must be maintained for inspection. The second and third steps are left to the supplier who will acknowledge your order and will confirm the quantities shipped to your pharmacy and the date the controlled substances were shipped to the pharmacy. The fourth and most important step is for the pharmacy to confirm the quantities of controlled substances received and the date received by the pharmacy.You must use 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 ascertain that you received all that was ordered and that the items in the tote are accurately listed on the invoice, go to the CSOS screen and confirm each item that you received. The following step is my recommendation and not required by DEA regulations.Print out a copy of the DEA Form 222 that you confirmed through CSOS and staple it to the invoice. File your DEA 222s on a monthly basis. These simple steps will enable you to retrieve executed DEA Forms 222 should you be required to provide them. Make sure you get a DEA Form 12 which is a DEA receipt if they take your original paper order forms. Some suppliers will tell you that you don’t need to print them out. They are right. Following their suggestions will put you behind your CSOS computer for days especially if DEA ask for two years’ worth of executed,canceled and voided order forms.Saving your Schedule II invoice as a substitute for the order form is not permitted by the regulations. DEA will tell you that they are secondary records and what they want are the paper or the electronic order forms. The regulations are very clear that DEA has the right to ask for,review and copy all order forms for the last two years. All you have to do is to provide them. How you do that is your decision. If you follow these steps you should never have a problem with DEA as long as the person ordering has their own CSOS password and you maintained a copy of your DEA Forms 222 in either the paper or electronic format. The regulations on CSOS and the DEA requirements for ordering Schedule II controlled substances can be found on the website www.deadiversion.usdoj.gov. 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 15
Custom Rx Connection August 2012
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