Did you know that October is the National Substance Abuse Prevention Month? In keeping with that theme, this episode of Talking with the Toothcop is all about drug regulatory issues and updates, schedule II drug monitoring, and substance abuse prevention. We share some helpful resources and DEA regulation updates—don’t miss it!
Outline of This Episode
- [1:33] DEA drug regulatory changes
- [3:53] Medicare consolidating credentialing in TX
- [4:28] Electronic 222 forms for schedule II drugs
- [6:36] Why you NEED to keep inventory
- [9:34] The topic of background checks
- [12:27] Substance Abuse Prevention Month
- [13:32] Controlling patient information
- [14:42] Annual DEA CE now required
- [15:17] How to check a patient’s drug history
- [21:36] The Professional Recovery Network
The DEA is making bank
The DEA is raising their fees. Effective 10/1/2020, the DEA registration fee is going from $721 to $888 per registration. For those of you that have multiple practices or registrations, it will get expensive.
What else is changing? The DEA will now require electronic 222 forms. You must fill out a 222 form to send to the DEA to order controlled substances for office use. You can use up the paper 222 forms until 10/31/2021. But what you don't use will have to be shredded.
We recommend that you don’t keep too many of these forms on hand—or too many controlled substances. If they expire, you have to send them to a reverse distributor. You can’t send them to the supplier you purchased them from. The fees you have to pay for expired drugs costs more than purchasing them in the first place.
Why you NEED to keep inventory
There are TWO things I recommend you do consistently:
- You need an up-to-date drug log and inventory. The DEA requires an inventory count every-other-year. Track the total on-hand. Track each concentration and form separately.
- Routinely get out your receipts and 222 forms and check your math. Make sure you aren’t missing anything.
Doing these things help prevent improper use and abuse of controlled substances. I’ve seen situations where staff members order extra bottles that disappear. If someone is using your credentials to perform duties related to controlled substances—trust but verify. They’re called controlled substances for a reason.
Do your background checks
Dental offices need to do background checks on employees. Some states are only allowed to allow full background checks in limited situations, such as when you’ve made a conditional job offer. But the DEA requires that anyone who works with controlled substances has a background check done on them. Ideally, it’s a full criminal background check.
If you won’t do a background check, you must do a basic screening for abuse or misuse potential. Secondly, if a staff member handles or prepares subscriptions, put the designation in writing and maintain a record of that. Most dentists are more comfortable doing the ordering themselves and I support that. If you use a designated agent or a power of attorney, you’re still responsible for overseeing their activities.
How do you check a patient’s drug history? When do you need to? What are some unexpected schedule II drugs? Listen for the details.
The Professional Recovery Network
If you or a dentist you know has a drug problem or mental health issue, there are professional recovery networks available. If you turn yourself in, you can get services confidentially. If a staff member turns you in it becomes a public health issue and it will be attached to your license. Keep yourself accountable. Don’t face emergency suspension of your license. If you or someone you know has a problem, be proactive and get help.
If you’re going through a rough time in your life they can help. It doesn’t have to be severe drug abuse. It’s okay to say you’re not okay and reach out for help. Don’t wait until you get arrested for a DWI. Substance abuse isn’t the number of times you’ve done it. It’s the reason why you’re doing it and the fact that you did it in the first place.
Andrea points out that everyone is human. No one plans on becoming an addict. It takes one opportunity. One bad decision. No one says “I’m probably going to get hooked on it, but it’s okay. It’s worth it.” Don’t give yourself or someone else the opportunity to make one bad decision. Put systems in place to protect you from yourself as much as you keep your staff accountable. It doesn’t matter if you claim you’re a good guy, you have to walk the talk. Learn what else is changing and more valuable resources by listening to the episode!
Resources & People Mentioned
- Pizza Hut Commercial
- Designated Agent Screening Form
- DEA Power of Attorney Format
- Role of Authorized Agents in Communicating Controlled Substance Prescriptions to Pharmacies
- Goodhire (background check)
- PMP CE Option
- Controlled Substances
- Professional Recovery Network: 800-727-5152