Veterinary Controlled Substances Compliance
Many veterinary practices would fail a federal or state
controlled substances regulatory audit or security inspection if it were held today.
Are you willing to take that risk?
The threat is REAL.
The opioid crisis has resulted in
more federal and state resources being
put toward preventing drug diversion.
DEA and state agency inspections
are often unannounced.
Average fine levied per case.
TAKE OUR FREE
RISK ASSESSMENT QUIZ
We know the DEA,
because we’ve been the DEA.
150+ collective years of law enforcement,
security and private-industry experience.
Founded by Retired DEA Supervisory
Special Agent: Jack Teitelman
Average federal fines levied per year.
What We Do
DEA compliance rules and regulations are more complicated than ever, and unannounced visits to veterinarian practices by both federal and state agencies are increasing.
Our full suite of DEA compliance and drug diversion-prevention services help assess your risk, provide remedial solutions and let you focus on what you do best: care for animals.
DEA compliance and drug diversion-prevention services
DEA Risk Assessment
Onsite assessment of your end-to-end control environment, with a scorecard that evaluates compliance and identifies risks.
One-day announced and unannounced mock-DEA investigations approximates the intensity of a real inspection and identify gaps in your team’s performance.
Regulatory Compliance Audit
In-depth review of your controlled-suvstance policy and procedures, to ensure accreditation and/or regulatory compliance.
Report & Recommendations
We provide a detailed report of findings — post mock-inspection and/or compliance audit —delineated by CSA code section / Title 21 of the CFR, and provide recommendations for remediation.
Work directly with you to develop a remediation plan Standard Operating Procedure (SOP) manual that guides the maintenance of an in-control business operation.
Review employee hiring and screening practices, drug-testing systems and background-check processes to lower the risk of hiring at-risk individuals.
Training & Education
Post-remediation training courses keep your entire staff updated on procedural changes, current trends and proactive anti-diversion measures.
Our team-based structure ensures appropriate, effective and discreet client focus, and is designed to make doing business with TITAN simple, before, during and after our engagement.
Veterinary practitioners often think, “We’ve always done things this way.” Or, “It can’t happen to me.” Neither is the best risk-mitigation strategy.
Your complete diversion
prevention assessment includes:
- Thorough report on the risks and gaps in your facility’s handling of controlled substances
- Recommendations/options for process improvement
- Implementation plan where we work with your team to make improvements
It can happen to you.
Whether it’s a trusted employee, long-time client or even a relative, veterinary practices are at risk for drug diversion.
It’s imperative that you be prepared. Now is the time to investigate, identify, correct and strengthen your veterinary practice against the most common vulnerabilities you face today. Keeping up with changing standards, best practices, new requirements and growing threats are the most effective ways to protect your business. But failing to adapt to these new realities may not only cost you financially, it can also cause irreparable harm to your personal and professional reputation.
Today’s DEA rules and regulations are so complex, business owners and practitioners struggle to understand what they should be doing.
Plus, the opioid crisis has resulted in more federal and state resources being put toward preventing drug diversion. And, the pressure is on investigators to step up controlled-substance compliance programs and conduct even tougher oversight.
Hefty civil fines are being levied against non-compliant individuals and businesses across the healthcare industry, including veterinary practices. The current federal fine per infraction is $15,040. But, it’s not uncommon for fines to exceed $1 million, not including the risk of having your DEA registration revoked and the negative fallout from publicity.
Source: DEA (2003-09). With increased inspections and a 45% increase in the average fine, it is estimated that these numbers may actually be 25% or more higher in recent years.
Vets treating large animals or working at horse tracks can be prime targets for individuals seeking to abuse anabolic steroids.
Source: Pharmacy Times, 7/31/17
Most common violations cited by the DEA:
Poor Veterinary Record-Keeping
Failure to Prevent Drug Diversion
Lack of Physical Security
DEA Registration Issues
In 2017, drug overdoses killed more Americans than the Vietnam and Iraq wars combined.
Driven by the current opioid crisis, DEA and state agencies have dramatically stepped up regulatory inspections on healthcare providers who use, dispense or prescribe controlled substances, including veterinarians.
We engaged TITAN for a gap analysis, which was a very easy process. They identified our strengths and weaknesses and we decided to go ahead with a full audit. Now if the DEA comes knocking, we’ll be 100% compliant.”
In one case involving a veterinarian, a dog owner tried to obtain hydrocodone to maintain his addiction. He even trained his dog to cough on cue.
Source: Pharmacy Times, 7/31/17
America’s drug crisis could be a crisis for your business too.
It’s not a matter of if drug diversion will take place, but a matter of when.
If you’ve been worrying about your own level of compliance risk, it may already be too late. Let us help you TITAN-up your DEA compliance.
Having the right plan and the right partner can mean the difference between quiet resolution and public indictment. To assess the risk in your business, take the free TITAN Risk Assessment Quiz.
The Titan Group DEA was founded by a retired DEA Supervisory Special Agent and is a full-service regulatory compliance, drug security and anti-diversion solutions provider.
With 150+ collective years of law enforcement, security and private-industry experience, the TITAN team of experts helps veterinary practices stay compliant, avoid penalties and deter criminal activities.
Don’t worry. We can help.
Veterinary DEA Form Resources
DEA Form 41
Registrant Record of Controlled Substances Destroyed.
Destruction of Controlled Substances
Form 41 is essentially a record of controlled substance inventory, drug disposal/destruction and medical waste disposal and must be kept available for at least 2 years.
It can only be submitted/utilized by a person registered and authorized by the DEA to handle controlled substances.
You must have a valid DEA registration and valid DEA registration number.
DEA Form 41 covers:
- Section A. Registrant Information
- Section B. (1) Inventory
- Section B. (2) Collected Substances
- Section C. Method of Destruction
- Section D. Witnesses
You are not required to submit this form to the DEA unless you’re requested to do so.
It is recommended that registrants review 21 CFR §1317 — Disposal
DEA Form 106
Theft or Loss of Controlled Substances.
Submitted/utilized only by a person registered with the DEA to handle controlled substances.
Federal regulations require that registrants notify the DEA Field Division Office in their area, in writing, of the theft or significant loss of any controlled substance within one business day of discovery of such loss or theft.
The registrant shall also complete and submit to the Field Division Office in their area, DEA Form 106, “Report of Theft or Loss of Controlled Substances” regarding the theft or loss. (21 C.F.R. § 1301.76(b))
DEA Form 106 covers:
- Section 1. Authentication and Report Selection
- Section 2. Theft/Loss Details
- Section 3. Controlled Substances
- Section 4. Signature
- Section 5. Theft/Loss Summary
- Section 6. Controlled Substances Summary and Certification
- Section 7. Submit Report
- Section 8. Print
For more information regarding reporting theft or loss of controlled substances, see the Federal Register Notice – “Reports by Registrants of Theft or Significant Loss of Controlled Substances.“
DEA Form 106 Online
DEA controlled substance registrants are strongly encouraged to complete and submit the DEA Form 106 online. In addition to being more convenient, completing the form online results in fewer errors. A link to the online DEA Form 106 is provided below.
DEA Form 106 Online
If a registrant does not have internet access, a paper copy of the DEA-106 form can be requested by writing to:
Drug Enforcement Administration
Attn: Regulatory Section/DRG
8701 Morrissette Drive
Springfield, VA 22152
DEA Call Center 1-800-882-9539.