Ensuring your practice is prescribing and documenting medications appropriately can get complicated. Here are some of the common violations seen by the Missouri Bureau of Narcotics and Dangerous Drugs (BNDD) and how to avoid them.
1. Allowing your registration to expire.
In both Missouri and Kansas, your registration to prescribe controlled substances has to be renewed annually. If you do not have your own DEA number, you can administer and use the drugs in a clinic owned by a primary veterinarian under their number; however, veterinarians need their own in order to write prescriptions. In Missouri, registrations have to be made at the veterinarian’s primary practice location, but veterinarians can travel and write prescriptions anywhere. In Kansas, a separate registration is required at each place of business or professional practice. If you practice in two states, you’ll need to register in both states.
2. Moving without notifying the BNDD in Missouri, or Board of Pharmacy in Kansas.
If your primary practice location changes, you need to update your registration prior to moving. Failing to do so makes your registration invalid.
3. Failing to maintain an annual drug inventory or document controlled substances prescriptions in patient charts.
Drug inventories should be done annually. The BNDD recommends keeping a continuous inventory as each drug is dispensed, and reconciling that inventory with products on the shelf every so often. Patient charts should also be updated on an ongoing basis. If you store controlled substances in more than one location, you should keep a master list of the drugs on the premises in each place. In addition, if veterinarians have separate registrations, each registrant’s drugs have to be kept physically separate from the others as well as inventoried separately.
4. Failing to document invoices used for tracking the receipt of drugs.
Always keep records documenting the receipt of controlled substances, such as invoices, DEA Official Order Forms, receipts for samples, or transfer records. Veterinarians with separate registrations need to keep their receipts separate as well.
5. Disposing of drugs without a witness and proper documentation.
Patient-contaminated drugs can be destroyed on-site with two people present. You need to document the date, drug name, form, quantity destroyed, reason for waste, and the names of those who destroyed the medications. Uncontaminated drugs can be destroyed with DEA permission, transferred to another DEA registrant, or transferred to a reverse distributor for destruction. (The latter option is the one preferred by the Kansas Department of Health and Environment). Regardless of the option chosen, proper documentation must be kept, and DEA forms 41 and/or 22 must be submitted.
6. Dispensing drugs in unapproved containers or without proper labeling.
All controlled substances must be in child-proof containers, unless they are samples provided to practitioners in FDA-approved, pre-packaged containers. Labels should include the date the prescription is dispensed, name and address of the pharmacy, patient’s name, drug name, strength, dosage form and quantity, and directions for administration. All controlled substances also need a warning label telling the patient transferring the medication is illegal.
