DEA Form 222: Control and Comply
A Complete Guide to DEA Form 222
(Psssst: If your organization uses the electronic DEA Controlled Substance Ordering System (CSOS), you have different usage and recordkeeping requirements. Contact TITAN to learn more about how we can help with your CSOS.)
What is a DEA Form 222?
DEA Form 222 is the single-page form used to purchase or transfer Schedule 1 or 2 controlled substances. The form is specifically designated for each DEA registration number you hold: if you have two registrations, for example, you cannot use the forms from one registered location to make purchases for the other location.
How do I get forms?
Getting forms is easy: Go to the DEA Diversion Control Division’s webpage for “DEA Forms & Applications”, simply click the request button, and log in. You’ll receive a package of forms by mail (the number of forms is based on the type of registration you hold). Simple! Having trouble? Call your local DEA Diversion Field Office and they can place the order for you.
TITAN TIP: Each DEA Form 222 has a unique form number and includes the registrant’s name, address, and registration number, the registrant’s authorized activity (e.g., “Practitioner”), and drug schedules the registrant is permitted to have. If you spot errors on your form, DO NOT write in corrections: contact your local DEA Diversion Field Office to report the mistakes.
How do I fill out the form?
- Use a typewriter, computer printer, pen, or indelible pencil.
- Put each item you’re ordering on its own numbered line. Note the number of lines completed at the bottom of the form in the space provided.
- Each DEA Form 222 must be signed and dated by a person authorized to sign a registration application or a person granted power of attorney (See below re: Do I Need a Power of Attorney?).
- Make a copy of your original DEA Form 222 for your records and then submit the original version to your supplier.
- When your medication order arrives in the office, write on your copy the actual number of commercial or bulk containers you received and the date they came.
- Keep a copy of each executed DEA Form 222 and all copies of unaccepted or defective forms with any receipts, invoices or statements attached.
Remember: Your form must be complete, legible, appropriately signed, and cannot have any alterations, erasures, cross outs, or other types of changes. If not, your supplier will refuse to fill your order.
Do I need a Power of Attorney?
The DEA Form 222 can be executed with the use of a typewriter, computer printer, pen or indelible pencil according to the DEA.
Only the DEA registrant and a person to whom the registrant has granted signing authority via a properly executive Power of Attorney form may sign the 222 form. A Power of Attorney form (you can create your own or TITAN can help you find one), when signed by you and witnessed, allows a member or your team to use your DEA registration to make Schedule 2 controlled substance purchases. You are NOT required to issue a Power of Attorney: if you want to retain control of all ordering under your DEA registration, you can do so.
I’m Going out of business or surrendering my DEA registration. What do I do?
If your DEA registration will end for some reason (e.g., retirement, closing your practice, changing your corporate entity, license suspension or revocation), you must return all unused DEA Forms 222 to the agency. Contact your local office for the best way to submit the forms.
TITAN TIP: If part of closing your business or losing your DEA registration will involve transferring Schedule 2 controlled substances to another registrant, DO NOT cancel your DEA registration or return your unused forms to DEA until the transfers are completed. Without an active registration or related forms, you won’t be able to legally complete any transfers.
What if my forms are lost or stolen?
Contact your local DEA office immediately and report it. Ideally, you should provide them with the identification number of each missing form. If you don’t have the numbers, provide an exact (or at least approximate) date of when you ordered the forms. If you find the missing forms later, notify the local DEA field office immediately.
How long do I keep executed 222 forms?
All executed forms must be kept for two years for DEA’s purposes (check your state requirements – it could be longer) and must be readily retrievable if you’re inspected. And don’t forget: if you have multiple DEA registrations, the paperwork must be separated by registration numbers.
TITAN’s TIPS - Common mistakes with DEA Form 222
Here are some of the most common mistakes and security lapses we see constantly:
- Leaving unused forms in easily accessible, unlocked storage.
- Failing to keep lists of each form’s unique number (Pro Tip: Add the date you use each form).
- Pre-signing forms.
- Failing to retain copies for two years and not having them readily retrievable.
- Mixing 222 forms in with other documentation, or mixing together 222 forms from multiple locations.
- Trying to submit a form to a distributor with changes, alterations, erasures or cross outs.
- Failing to report missing or stolen forms.
- Failing to fill out the receiving portion of the form (Part 5) once your medication order arrives.
- Letting staff members without Powers of Attorney complete and submit forms to suppliers.
- Permitting too many staff members to have Powers of Attorney (and failing to cancel them once the employees leave).
- Letting the same person place, receive and unpack the orders. Separating duties adds extra eyes to the process to spot unusual or illegal order.
TITAN wants to be sure you’re doing everything possible to stay compliant with your recordkeeping.