Receiving a DEA registration is a major milestone for an EMS agency, but the work doesn't stop once the certificate arrives. The first 90 days are an essential opportunity to establish compliant processes, reinforce employee expectations, and identify small issues before they snowball into bigger problems that can bury you in an avalanche of violations during a DEA inspection.
TITAN Group created this unique“EMS Agency 90-Day Checklist” based on our years of helping companies across the country navigate the confusing regulations DEA enforces.
Implementing new controlled substance handling procedures can be stressful for employees. During the first few months, supervisors should closely review documentation with all members of the team, provide quiet coaching when corrections are needed, and reinforce proper recordkeeping and security practices.
The goal: make sure everyone not only understands the procedures but consistently follows them.
DEA recordkeeping requirements are very specific and require specific types of information. Go over any inventory forms, logs, or report templates you've create to ensure you not only have them all but that they contain all required information. Did you get templates from another agency or find them online? Be sure you’re not adopting someone else’s mistakes. Using electronic recordkeeping? Confirm that your system can quickly and easily generate records the DEA expects to see such as drug disposal reports, biennial inventories, and purchase records. If records aren't readily retrievable during an inspection, your agency could face unnecessary compliance issues and violations.
TITAN Tip: Be sure to ask us about the simple electronic solution: SageComply.
If your agency will be using Powers of Attorney (POAs), execute them promptly and retain them in your records. Don’t worry: there's no need to send them to DEA unless specifically requested.
Another vital administrative task: cleaning up transition paperwork. If you've recently transitioned to operating under your own DEA registration after years of obtaining controlled substances through a hospital, verify that all drug transfers from the hospital were completed correctly, inventories are accurate, and all other paperwork is complete so there are no mistakes or problems lurking in your files.
At TITAN, we tell all of clients no matter how big or small they are: "Two is one, and one is none."
This well-known military principle applies directly to DEA compliance. Ensure more than one employee understands your recordkeeping systems, ordering procedures, and security responsibilities. Cross-training key personnel helps maintain compliance if someone is unavailable, provides a second set of eyes to spot problems, ensures all data and records are readily retrievable, and reduces operational risk.
Your staff has followed a certain set of rules for years when it came to controlled substances. But having a DEA registration means new ways of doing business with new recordkeeping systems on top of new processes and procedures. Ask the “hands on staff” who are in the field day to day which changes are working well and what could be improved. Employee feedback often identifies opportunities to simplify workflows, improve accuracy, and strengthen compliance before bad habits develop.
Don't assume security systems are working simply because they're shiny, new, and recently installed. Verify that alarms report properly, PINs or access credentials function as intended, cameras are recording correctly, and backup systems operate as expected.
TITAN Tip: Consider making security system testing part of your quarterly or semi-annual compliance verification routine not just a one-time exercise.
Store blank DEA Form 222s securely and maintain organized records with Schedule I documentation separated from Schedule III-V records. Make sure non-controlled records are not accidentally mixed in. Good organization not only improves efficiency but also demonstrates to any DEA investigator that your agency supports a culture of compliance.
Finally, put your DEA registration expiration date on your calendar. Renewing early—typically 30 to 60 days before expiration—helps avoid last-minute problems that could jeopardize your registration (what if you’re out of town when it’s due? Or computers crash?), forcing the agency to apply for an entirely new registration. Use the first 90 days of being a new DEA registrant to establish the compliance habits your agency will rely on for years to come. Investing a little extra attention now can prevent costly mistakes later.
Ready for a second opinion? Start with TITAN Group's FREE, no-charge 15-minute DEA Compliance Assessment — no obligation to move forward. We'll walk through your current program, flag any red flags, and give you a clear picture of where you stand.
Need more than a checkup? TITAN Group's consultants are former DEA investigators with a proven national track record helping healthcare organizations of every kind not just survive DEA compliance, but thrive under it. Don't wait for an audit to find your gaps. Contact TITAN Group today.