Today’s Veterinary Business provides information and resources designed to help veterinarians and office management improve the financial performance of their practices, allowing them to increase the level of patient care and client service.
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55 August/September 2017 • TODAYSVETERINARYBUSINESS.COM drugs. Any abuse may lead to moderate or low physical dependence or high psycho- logical dependence. • IV: Even lower potential for abuse. • V: Lowest potential for abuse. These drugs consist primarily of preparations containing limited quantities of certain narcotics. Most controlled drugs used in veterinary hospitals are classified under Schedules II, III and IV. Understand Basic Rules A current, original and address-spe- cific DEA license must be on file at the clinic and with drug vendors before a hospital can purchase, store or dispense controlled sub- stances. Each veterinarian who pre- scribes controlled substances that a client then obtains elsewhere must obtain a separate DEA registration. Additional and separate ad- dress-specific DEA registration numbers are required: • If a doctor orders, oversees or dispenses controlled sub- stances at more than one hospital. • When the ordering, storing and dispensing is separate and distinct from the primary hospital environment, such as at a satellite clinic or animal shelter or with an unaffiliated house-call practice. Additional and separate ad- dress-specific DEA registration numbers are not required when: • The activities are considered an extension of hospital-based ordering and dispensing. • House-call services or in- home euthanasia is per- formed using a registered hospital as a home base. Take Precautions The diversion of controlled sub- stances in the veterinary profession is rampant. Establishing a drug-free workplace is essential, as is perform- ing pre-employment background and drug screenings of all potential new hires, including veterinarians. Several states require background checks and additional screenings of employees who have access to controlled substances. Establishing procedures and protocols is essential in main- taining the security of controlled substances. Unopened contain- ers — your back stock — must be securely stored in an immoveable cabinet. This means something that is attached to the building, such as a wall safe. Opened containers in active use may be stored in a locked, less substantial, immobile cabinet or drawer during working hours. All supplies are to be locked in sub- stantial cabinets when not in active use, which means they must be re- turned to the most secure location at the end of the day. Schedule II drugs must be stored separately from those in schedules III, IV and V. This can be accomplished by placing them on separate shelves in the drug safe. If controlled substances such as the anesthetic agent Telazol are to be stored in a refrigerator, they should be placed in a locked box attached to a shelf. A refrigerator lock would be appropriate. Maintain Paper Trail Proper recordkeeping is an essen- tial step in maintaining controlled drugs. Usage logs are required for all controlled substances when they are administered in or dis- pensed from the practice. That means every milliliter, tablet, cap- sule and patch. Schedule II logs must be stored separately from Schedule III, IV and V logs. The records should be bound, although loose-leaf binders with clear dividers are acceptable. Entries should be made in black or blue ink. Using a pencil or correction fluid or making alterations is not acceptable. The way to handle a mistaken entry is to draw a line through it and add a brief explana- tion and your initials. Logs should include: • Date of activity • Client name • Client address or unique chart number • Patient name • Amount used or dispensed • Balance after use • The drug handler's initials (not just the doctor who pre- scribed or ordered the drug) Drug logs kept within practice management software are accept- able if the above information is entered and is unalterable. Know Your Numbers Logs should be reconciled and bal- anced as you go rather than weekly or monthly. Discrepancies or math errors caught early are easier to fix. In addition to logging require- ments, the DEA requires a full and complete inventory count at these specific intervals: • Initial inventory: With con- trolled substances engage- ment, such as upon opening or purchasing a practice • Biennial inventory: Every two years thereafter • Closing inventory: When a practice is closed or sold Although the DEA requires counts only every two years, more frequent checks are a good idea. Remember that all logs are re- quired to be retained for at least two years and kept onsite. Outdated, damaged, unusable or unwanted controlled drugs require proper disposal. The DEA offers drug-disposal information at http://bit.ly/2s8pfa3. An increasing number of individual state agencies require additional reporting of controlled substances when dispensed to a client for home use, so check the DEA website or with your local vet- erinary medical association or state licensing board. When you and your team understand the regulations and the importance of having good systems in place, managing con - trolled substances will not be such a daunting task. Getting Technical columnist Sandy Walsh is a practice management consultant, speaker, writer and instructor for Patterson Veterinary University. POPULAR VETERINARY DRUGS Schedule II • Hydromorphone • Morphine • Fentanyl • Oxymorphone • Pentobarbital sodium • Demerol Schedule III • Hydrocodone (Tussigon) • Ketamine • Telazol • Buprenex (Buprenorphine) Schedule IV • Alfaxan (Alfaxalone) • Diazepam (Valium) • Alprazolam • Phenobarbital • Torbugesic (Butorphanol) • Tramadol