CVPM Controlled Substances & DEA Compliance 5 — Questions and Answers
Question 1: A locum tenens veterinarian working at a practice does not have a DEA registration. Under which circumstance may they legally administer a Schedule III controlled substance from the practice's stock?
- If the practice manager provides written authorization
- Never; they must obtain their own DEA registration first
- If they are employed under the DEA registration of the practice's registered veterinarian and operating within that registrant's oversight (Correct answer)
- If the state veterinary board grants a temporary permit
Correct answer: If they are employed under the DEA registration of the practice's registered veterinarian and operating within that registrant's oversight
An unregistered veterinarian may dispense or administer controlled substances within the registration of a DEA-registered veterinarian under whose authorization and supervision they work, per DEA guidance on agents/employees.
Question 2: A practice manager is reviewing the biennial DEA controlled substance inventory. Which statement about this inventory is CORRECT?
- It must be conducted exactly on the 2-year anniversary of the last inventory
- It must be completed within 2 years of the previous inventory and can be conducted on any day within that window (Correct answer)
- It requires a DEA inspector to be present
- It only applies to Schedule II substances
Correct answer: It must be completed within 2 years of the previous inventory and can be conducted on any day within that window
The biennial inventory must be completed within every 2-year period from the prior inventory date; the specific date within that window is chosen by the registrant.
Question 3: Which of the following is the appropriate method for disposing of expired Schedule II controlled substances at a veterinary practice?
- Flush them down the drain with a witness
- Transfer them to a DEA-authorized reverse distributor or use a DEA-authorized disposal method (Correct answer)
- Destroy them in the autoclave and document it
- Return them to the manufacturer with a completed DEA Form 222
Correct answer: Transfer them to a DEA-authorized reverse distributor or use a DEA-authorized disposal method
Expired Schedule II substances must be transferred to a DEA-authorized reverse distributor or disposed of via a DEA-approved method such as a take-back event or on-site destruction per DEA regulations.
Question 4: During a DEA inspection, an agent asks to see the controlled substance perpetual inventory log. The log shows an unresolved discrepancy from 6 months ago. What is the LIKELY consequence?
- A warning letter only, since no criminal activity is proven
- Possible civil or criminal penalties for failure to maintain accurate records (Correct answer)
- Automatic suspension of DEA registration pending investigation
- No consequence if the discrepancy is under 5%
Correct answer: Possible civil or criminal penalties for failure to maintain accurate records
Unresolved discrepancies in controlled substance logs may result in civil or criminal penalties under the Controlled Substances Act for failure to maintain accurate records.
Question 5: A veterinary practice wants to add a second satellite clinic location to its existing DEA registration. What must the practice do?
- Submit a written amendment to the existing DEA registration
- Obtain a separate DEA registration for each additional location where controlled substances will be stored or dispensed (Correct answer)
- Notify the DEA by phone and receive verbal approval
- Add the new location on the next biennial registration renewal form
Correct answer: Obtain a separate DEA registration for each additional location where controlled substances will be stored or dispensed
Each location where controlled substances are stored or dispensed must have its own DEA registration; one registration cannot cover multiple physical locations.
Question 6: A client's horse requires ketamine for a field procedure. The attending veterinarian is DEA registered. Which documentation is the MINIMUM required at the time of administration?
- A written prescription signed by the veterinarian
- An entry in the controlled substance log noting the date, patient, quantity used, and administering veterinarian (Correct answer)
- A DEA Form 222 completed prior to use
- A client authorization form witnessed by a second staff member
Correct answer: An entry in the controlled substance log noting the date, patient, quantity used, and administering veterinarian
The minimum requirement is a contemporaneous log entry recording the date, patient, amount used, and responsible veterinarian, as required by DEA recordkeeping rules.
Question 7: A veterinary practice manager discovers that a team member has been diverting small amounts of buprenorphine over several months. After confirming the diversion, what is the CORRECT sequence of actions?
- Terminate the employee, conduct internal review, then file DEA Form 106 within 1 business day
- File DEA Form 106, notify local law enforcement if required, document the investigation, and review access controls (Correct answer)
- Counsel the employee, place them on probation, and monitor for 90 days before escalating
- Contact the state pharmacy board exclusively, as DEA reporting is optional for veterinary practices
Correct answer: File DEA Form 106, notify local law enforcement if required, document the investigation, and review access controls
Confirmed diversion requires filing DEA Form 106 to report the theft/loss, notifying law enforcement as applicable, thorough documentation, and corrective access controls.
CVPM Controlled Substances & DEA Compliance 5
A locum tenens veterinarian working at a practice does not have a DEA registration.
Under which circumstance may they legally administer a Schedule III controlled substance from the practice's stock?