CVPM Controlled Substances & DEA Compliance 2 — Questions and Answers
Question 1: A veterinary practice needs to dispose of expired controlled substances. What is the DEA-approved method?
- Flush them down the drain with a witness present
- Use an authorized DEA reverse distributor or an approved drug take-back program (Correct answer)
- Incinerate on-site and document the destruction internally
- Return directly to the original manufacturer without DEA involvement
Correct answer: Use an authorized DEA reverse distributor or an approved drug take-back program
DEA regulations require that controlled substances be disposed of through a DEA-authorized reverse distributor or an approved drug take-back program to ensure proper documentation and prevent diversion.
Question 2: Buprenorphine, when used in veterinary practice, is classified under which DEA schedule?
- Schedule I
- Schedule II
- Schedule III (Correct answer)
- Schedule IV
Correct answer: Schedule III
Buprenorphine is classified as a Schedule III controlled substance due to its lower potential for abuse compared to Schedule I and II substances and its accepted medical use.
Question 3: The DEA 'corresponding responsibility' doctrine in controlled substance prescribing means that:
- Both the prescribing veterinarian and the dispensing pharmacist share responsibility for valid controlled substance prescriptions (Correct answer)
- The DEA and state pharmacy board share equal enforcement jurisdiction
- The practice manager bears equal legal liability as the DEA registrant veterinarian
- Schedule II and III drugs require identical documentation from all staff
Correct answer: Both the prescribing veterinarian and the dispensing pharmacist share responsibility for valid controlled substance prescriptions
Corresponding responsibility means the pharmacist (or dispenser) shares responsibility with the prescribing veterinarian to ensure that a controlled substance prescription is issued for a legitimate medical purpose.
Question 4: According to DEA regulations, a veterinarian may prescribe controlled substances for animals only when there is a valid:
- State-issued controlled substance license
- Direct line-of-sight supervision arrangement
- Veterinarian-Client-Patient Relationship (VCPR) (Correct answer)
- Board-certified specialty credential
Correct answer: Veterinarian-Client-Patient Relationship (VCPR)
A valid VCPR is a prerequisite for prescribing any controlled substance; without it, the prescription lacks a legitimate medical purpose required by the DEA.
Question 5: When a veterinary practice submits a DEA Form 222 to order Schedule II substances, which copies go to the supplier and which is retained by the practice?
- Copy 1 only goes to supplier; Copies 2 and 3 retained by practice
- Copies 1 and 2 go to the supplier; Copy 3 is retained by the practice (Correct answer)
- All 3 copies go to the supplier who then returns one
- Copy 3 goes to the DEA; Copies 1 and 2 retained by practice
Correct answer: Copies 1 and 2 go to the supplier; Copy 3 is retained by the practice
On DEA Form 222, Copies 1 and 2 are sent to the supplier (who forwards Copy 1 to the DEA and retains Copy 2), while Copy 3 remains with the purchasing practice as the official record.
Question 6: A veterinary technician is confirmed to have diverted controlled substances from the practice. What is the correct course of action for the practice manager?
- Issue a written warning and increase supervision
- Secure all records, conduct an internal investigation, involve law enforcement, and report to the DEA using Form 106 (Correct answer)
- Transfer the employee to administrative duties pending an HR review
- Terminate the employee immediately and seal all drug cabinets without further action
Correct answer: Secure all records, conduct an internal investigation, involve law enforcement, and report to the DEA using Form 106
Confirmed diversion requires securing evidence, notifying law enforcement, and reporting to the DEA on Form 106, as federal law mandates reporting theft or significant loss of controlled substances.
Question 7: Which of the following is NOT a required element in a veterinary controlled substance administration log?
- Name of the patient/animal receiving the drug
- Date and time of administration
- The prescribing veterinarian's home address (Correct answer)
- Quantity administered
Correct answer: The prescribing veterinarian's home address
A controlled substance log must capture patient name, date/time, drug name, quantity, and administering/prescribing personnel—but personal residential addresses are not a DEA documentation requirement.
CVPM Controlled Substances & DEA Compliance 2
A veterinary practice needs to dispose of expired controlled substances.
What is the DEA-approved method?