Assess your own risk.
Take the quiz.
Answer these six questions to evaluate the level of risk in your practice.
Question 1 of 6
Do you have a DEA regulatory inspection “ready and retrievable” file that contains all your required DEA documentation (i.e., power of attorney for ordering drugs, state medical licenses, DEA registration certificate and copy of initial inventory, biennial inventory)?
Records kept by automatic data processing systems or other electronic or mechanized recordkeeping systems in such a manner that they can be separated out from all other records in a reasonable time, and/or records kept in such a manner that certain items are asterisked, redlined or in some other manner visually identifiable apart from other items appearing on the records.
Answer YES if...
you are 100% sure that your required DEA documentation is current and contained in a “ready and retrievable” file.
Answer NO if...
your required DEA documentation is not up-to-date, not contained in a “ready and retrievable” file or both.
Answer I DON’T KNOW if...
you are not 100% sure that you have all required DEA documentation on file, that it is up-to-date and that it is contained in a DEA-compliant “ready and retrievable” file.
Question 2 of 6
In the past five years, have you conducted a background investigation on new or existing employees, including a standard seven-panel-drug urine test for marijuana, cocaine, opiates, PCP, amphetamines, benzodiazepines and barbiturates?
Conducting background checks on all existing and new employees is necessary to ensure DEA compliance. 21 CFR §1301.76(a) states that “the registrant shall not employ, as an agent or employee who has access to controlled substances, any person who has been convicted of a felony offense relating to controlled substances.”
Answer YES if...
you are 100% sure that all employees in your facility (existing and new) have passed a thorough background check.
Answer NO...
if thorough background checks have not been conducted for all new and existing employees. Even if they have been partially conducted, still answer NO.
Answer I DON’T KNOW if...
you are not 100% sure that thorough background checks have been performed on all existing employees and new hires. If your policies and procedures do not require conducting thorough background checks for all employees, there is a good chance that this has not been done.
Question 3 of 6
Does your facility have an up-to-date controlled substance policy and procedure manual for establishing and maintaining effective controls and procedures to prevent diversion?
Standard operating procedures are not required by the DEA. However, they are highly recommended to ensure that all policies and procedures are conducted according to federal and state guidelines. “Up-to-date” means ensuring that policies and procedures exist and are regularly reviewed to direct all aspects of proper handling of controlled-substance medication to include ordering, storage, recordkeeping and use to comply with the Code of Federal Regulations (CFR).
Answer YES if...
you are 100% sure that the controlled-substance policy and procedure manual at your facility is up-to-date based on current DEA diversion prevention recommendations and requirements.
Answer NO...
if you don’t have a controlled-substance policy and procedure manual at your facility, or if it is not up-to-date.
Answer I DON’T KNOW...
if you are unsure whether your facility’s controlled-substance policy and procedure manual is up-to-date according to current DEA diversion prevention recommendations and requirements.
Question 4 of 6
Have you conducted a DEA controlled-substance mock audit within the past two years?
This is the most important factor in determining if you are at risk for non-compliance. A mock inspection will let you know if your facility is ready for the real thing by indicating where you may be lacking when it comes to your controlled-substance procedures and policies. A DEA-qualified auditor or company will be staffed by former DEA special agents and diversion investigators experienced at conducting controlled-substances audits and criminal investigations of diversion.
Answer YES only if...
a qualified DEA compliance auditor has visited your facility within the past two years and conducted a full audit based on current DEA requirements.
Answer NO if...
a mock audit has not been performed at your facility by a qualified DEA auditor within the past two years.
Answer I DON’T KNOW if...
you’re not sure if a mock audit has been performed at your facility by a qualified DEA auditor within the past two years.
Question 5 of 6
Does your facility have video surveillance for your controlled-substance storage?
Video surveillance is a DEA prevention-based recommendation (not mandatory). However, it is essential in the prevention and identification of internal theft/diversion.
Answer YES if...
you are 100% sure that all controlled substances at your facility are under 24/7 surveillance.
Answer NO if...
you do not have 24/7 video surveillance of all controlled-substance storage and inventory at your facility.
Answer I DON’T KNOW if...
you are not 100% sure that all controlled substances at your facility are under 24/7 surveillance.
Question 6 of 6
Do you have two authorized employees witness waste disposal of your controlled substances?
The DEA requires that all facilities have two authorized employees present anytime controlled substances are disposed of onsite. An “authorized employee” is someone who acts on behalf of, or at the direction of, the registrant to perform controlled substance activities.
Answer YES if...
you are 100% sure that all controlled-substance waste disposal at your facility is witnessed by two authorized employees.
Answer NO if...
all or part of your facility’s controlled-substance waste is disposed of without the presence of two authorized employees.
Answer I DON’T KNOW if...
you are not 100% sure that all controlled substance waste disposal is witnessed by two authorized employees.
