Resolve to Change

"June is the gateway to summer." - Jean Hersey 

With half the year already over and the warm months putting you in the mood for beaches and barbeques, the cold of January and your personal New Year’s resolutions are a dim memory. But maybe it’s time for a new tradition - “Half Year Resolutions”.  

In your role as a DEA registrant, these “half-year resolutions” can keep you and your staff on track for regulatory compliance while avoiding costly mistakes. Whether you’re running a busy pharmacy, veterinary clinic, or profitable company, now is the time to hit the compliance reset button and resolve to take a few simple actions that reinforce good habits, tighten your controls, and show DEA investigators (or state inspectors) that you take your responsibilities seriously. 

Not sure where to start? Here are TITAN Group’s suggestions based on the some of the most significant violations we see all the time in our work around the country: 

Resolution: “I will verify that my controlled substance records are complete, accurate, and readily retrievable.”

• Do a spot-check of DEA Form 222s, Power of Attorney records, biennial inventory, and invoices.
• Make sure your Schedule II records are not mixed with Schedule III-V records.
• Check for illegible handwriting, math mistakes, and sloppiness (are there crossed out entries? arrows pointing to other entries? ripped or missing pages?). 

Resolution: “I will limit controlled substance access to only those who need it—and properly document their authority, along with any related policies and procedures.”

• Review who has signing authority for DEA 222 Forms (check for a valid Power of Attorney, and be sure you’ve canceled authorizations of former employees).
• Confirm that only necessary employees have access to controlled substances. Remove access for former employees or staff who’ve changed roles.
• Review any relevant access control and security policies. Are they still applicable or should they be updated?

Resolution: “I will provide refresher training to staff on DEA compliance basics to reduce the risk of mistakes or drug diversion, and to be prepared for possible inspections.”

• Cover topics like proper documentation, reporting thefts/losses, and storage/security requirements.
• Discuss how to identify and report suspicious activity (especially for prescribing or dispensing).
• Be sure that staff know where all required records are stored, and who to contact if the DEA shows up demanding to see them. 

Resolution: “I will figure out where we’re vulnerable.”

• Take the TITAN Group’s risk assessment quiz [LINK] and see where you need to invest your time and energy. 
• Bring in TITAN Group to conduct a gap analysis or mock DEA inspection for a neutral, expert opinion. 
• Read TITAN Group’s library of helpful articles and guides – or sign up for one of our online training courses!

Why not finish out the year with compliance confidence? Turn those resolutions into proactive action - call TITAN today a(347) 723-8019. Then head out and enjoy the sunshine and that burger on the grill.