Transcript DEA Do’s & Don'ts for EMS - Home

DEA Do’s &
Don'ts for
EMS
OUR STORY AT KATY FIRE DEPT.
Overview
▪ Our Story
▪ What went wrong
▪ DEA 222’s
▪ Invoices
▪ Distribution
▪ Inventory
▪ Education
History
20+ years of EMS we have never had a DEA audit/Investigation
1 Medical Director
Numerous EMS Directors
All certifications were up to date (DEA, DPS, DSHS or TX Dept. Of
Health)
Protocols regularly reviewed and updated
CCTV with recording and Cyber keys in place for control measures
Log books in place
What went wrong
• Protocol change to phase out Valium and add Ativan
(Diazepam)
(Lorazepam)
• Surplus Valium in stock
• Valium should have been returned to vendor or
destroyed
What went wrong
▪ No one questioned the Boss
▪ The boss knew better than anyone
▪ The boss educated staff
▪ The boss wouldn’t do wrong
WHAT ELSE DID WE FIND?
APPROPRIATE BOXES MUST BE FILLED OUT &
LEGIBLE.
EACH INFRACTION OR MISSING 222 $10,000
Copy 3 will be for receiving
Packages received and date received
must be completed
Invoices
• Can be kept in two places
• On site
• City Hall/finance/records
Letter must be on file with the DEA
listing the address and intent to
keep invoices at a different
address than where scheduled
drug are delivered and stored.
Invoices & Packing slips are NOT
the same!!!
Packing slips should be signed
and dated to account for arriving
narcotics.
Keep invoices, packing slips, and
222 forms together and keep for 2
years
Each missing invoice is $10,000
Distribution
Agencies with multiple stations:
Power of Attorney
Cannot distribute from a central station
without licensure
You must have a power of
attorney on file to purchase and
distribute narcotic on behalf of the
medical director.
Cannot distribute narcotics to an ambulance
then post the ambulance (anywhere) for a
majority of the workday
Each station must be on file with DEA
Drugs must be delivered to that address for supply,
distribution, and usage.
1 POA for purchasing
1 POA for distribution
Biennial Inventory
Biennial Inventory (2yrs) of
scheduled drugs must be
completed and on file!
Education
Educate your personnel
Diversion education should be
part of new hire indoctrination
Continuing education on
diversion should be a part of your
training program
Once found, you have 24 hours to
report missing (LOSS or THEFT)
narcotics to the DEA!!! Form 106 or
call to DEA