DEA DEA Diversion Control 1 — Questions and Answers
Question 1: What is 'drug diversion' as defined in DEA enforcement contexts?
- The transfer of a legally manufactured controlled substance from its intended lawful use to an illegal use or market (Correct answer)
- Smuggling controlled substances across international borders
- Manufacturing counterfeit pharmaceuticals
- Using a controlled substance for a purpose other than its approved route of administration
Correct answer: The transfer of a legally manufactured controlled substance from its intended lawful use to an illegal use or market
Diversion is the redirection of legally produced controlled substances — such as prescription opioids — from their legitimate medical purpose into illicit channels.
Question 2: What is a 'pill mill' as targeted by DEA's Diversion Investigators?
- A medical practice or pharmacy that prescribes or dispenses controlled substances outside the course of professional practice for no legitimate medical purpose (Correct answer)
- A clandestine facility that manufactures counterfeit pills
- A pharmacy that dispenses in unusually large quantities for legitimate patients
- A wholesale distributor that sells to unregistered buyers
Correct answer: A medical practice or pharmacy that prescribes or dispenses controlled substances outside the course of professional practice for no legitimate medical purpose
Pill mills are clinics or physicians who prescribe controlled substances — typically opioids — without proper medical evaluation, effectively acting as retail drug dealers with prescriptions.
Question 3: Under DEA regulations, what is required of a DEA registrant that discovers a significant theft or loss of controlled substances?
- Notify DEA within one business day and submit a DEA Form 106 (Report of Theft or Significant Loss) (Correct answer)
- Notify local police only and file a report within 30 days
- Conduct an internal investigation before notifying DEA
- Report only losses exceeding 10% of monthly inventory
Correct answer: Notify DEA within one business day and submit a DEA Form 106 (Report of Theft or Significant Loss)
21 C.F.R. § 1301.76 requires registrants to immediately (within one business day) report significant theft or loss to the nearest DEA office and submit a DEA-106 form.
Question 4: What is 'doctor shopping' in the context of DEA diversion enforcement?
- A patient visiting multiple physicians to obtain multiple prescriptions for controlled substances without disclosing the other prescriptions (Correct answer)
- A practice where physicians recommend specific pharmacies to patients
- DEA investigators posing as patients to investigate prescribers
- Pharmacists filling prescriptions from multiple states for the same patient
Correct answer: A patient visiting multiple physicians to obtain multiple prescriptions for controlled substances without disclosing the other prescriptions
Doctor shopping is a diversion method where individuals obtain multiple prescriptions for controlled substances from different providers, circumventing individual prescribing limits.
Question 5: Prescription Drug Monitoring Programs (PDMPs) are used by DEA Diversion Investigators primarily to:
- Identify patterns of over-prescribing, doctor shopping, and other diversion indicators by analyzing prescription dispensing data (Correct answer)
- Track drug shipments from manufacturer to pharmacy
- Monitor foreign pharmaceutical imports
- Verify that pharmacies are maintaining proper DEA registrations
Correct answer: Identify patterns of over-prescribing, doctor shopping, and other diversion indicators by analyzing prescription dispensing data
PDMPs are state databases that record controlled substance prescriptions; DEA investigators use PDMP data to detect prescribing anomalies and diversion patterns.
Question 6: What is a 'DEA Form 222' used for?
- Ordering Schedule I and II controlled substances between DEA registrants (Correct answer)
- Reporting a theft or significant loss of controlled substances
- Applying for a new DEA registration
- Documenting the destruction of expired controlled substances
Correct answer: Ordering Schedule I and II controlled substances between DEA registrants
DEA Form 222 (or its electronic equivalent CSOS) is the official order form required for all transfers of Schedule I and II controlled substances between registered entities.
DEA DEA Diversion Control 1
What is 'drug diversion' as defined in DEA enforcement contexts?