DEA Drug Diversion Investigations & Enforcement 2 — Questions and Answers
Question 1: A pharmacist suspects a fellow employee of skimming opioids by short-filling prescriptions. What is the pharmacist's primary obligation under DEA regulations?
- Report the suspicion to the DEA field office
- Document the suspicion internally and monitor the employee
- Report the theft or significant loss to the DEA within one business day (Correct answer)
- Conduct an internal audit before involving any outside agency
Correct answer: Report the theft or significant loss to the DEA within one business day
DEA regulations (21 CFR 1301.76) require registrants to report theft or significant loss of controlled substances to the nearest DEA field office within one business day of discovery.
Question 2: During a diversion investigation, an agent identifies a physician who has issued prescriptions to deceased patients. This practice is best characterized as:
- Prescription forgery
- Doctor shopping
- Ghost patient prescribing (Correct answer)
- Off-label prescribing
Correct answer: Ghost patient prescribing
Ghost patient prescribing occurs when a practitioner issues prescriptions in the names of deceased, fictitious, or unknowing patients to divert controlled substances.
Question 3: Which DEA form must be completed when a DEA registrant discovers that controlled substances are missing and the cause is unknown?
- DEA Form 106 (Correct answer)
- DEA Form 222
- DEA Form 224
- DEA Form 41
Correct answer: DEA Form 106
DEA Form 106 (Report of Theft or Significant Loss of Controlled Substances) must be filed when controlled substances are stolen or significantly lost, including cases where the cause is unknown.
Question 4: In a pharmaceutical diversion investigation, 'cargo theft' most commonly refers to:
- Robbery of a pharmacy at gunpoint
- Theft of controlled substances during interstate shipment (Correct answer)
- Employee theft from a manufacturer's warehouse
- Shoplifting from a retail pharmacy
Correct answer: Theft of controlled substances during interstate shipment
Cargo theft in pharmaceutical diversion typically involves the theft of controlled substances during transport between the manufacturer, distributor, and pharmacy.
Question 5: A DEA investigator reviewing a pharmacy's ARCOS data notices that a small independent pharmacy is purchasing 10 times more oxycodone than comparable pharmacies in the same zip code. This is an example of:
- Statistical anomaly requiring no further action
- A potential diversion red flag warranting investigation (Correct answer)
- Normal variation due to patient population differences
- Proof of illegal activity requiring immediate arrest
Correct answer: A potential diversion red flag warranting investigation
Significant purchasing disparities compared to peer pharmacies are recognized red flags that warrant further investigation into potential diversion, though they alone do not constitute proof.
Question 6: Under the Controlled Substances Act, a 'mid-level practitioner' authorized to prescribe Schedule III–V controlled substances would include which of the following?
- A licensed pharmacist
- A registered nurse without prescriptive authority
- A physician assistant with state prescriptive authority (Correct answer)
- A pharmacy technician
Correct answer: A physician assistant with state prescriptive authority
Mid-level practitioners include physician assistants, nurse practitioners, and similar professionals who hold DEA registration and state authority to prescribe controlled substances.
Question 7: Which investigative technique is specifically used to determine whether a pharmacy's controlled substance dispensing records match its purchasing records?
- Covert surveillance
- Reconciliation audit (Correct answer)
- Undercover prescription purchase
- Trash cover
Correct answer: Reconciliation audit
A reconciliation audit compares controlled substance purchases against dispensing records and inventory to identify unexplained discrepancies that may indicate diversion.
DEA Drug Diversion Investigations & Enforcement 2
A pharmacist suspects a fellow employee of skimming opioids by short-filling prescriptions.
What is the pharmacist's primary obligation under DEA regulations?