Studying up for my state board exam and a question comes up... What does a pharmacist do with a 222 form that is either filled out incorrectly (significant mistakes, not minor spelling) or is damaged or is in some other way unusable? Thanks.
Damaged 222 Form
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That should not be on the state board exam unless your state has a unique procedure.
I've typically seen the form covered with a large "VOID" and stored in a secure location. The reason not to destroy them is that they are supposed to be used sequentially, and in the (extremely unlikely event) that the one that wasn't used in order was questioned, you'd have evidence of the reason it was not used and will not be used.
I've typically seen the form covered with a large "VOID" and stored in a secure location. The reason not to destroy them is that they are supposed to be used sequentially, and in the (extremely unlikely event) that the one that wasn't used in order was questioned, you'd have evidence of the reason it was not used and will not be used.
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Well the state board exam covers both federal and state laws right? It's up to the test taker to know which is stricter and applies to the question. Or at least that was how our law professor explained it. After all there is no "national law exam", right?
As for the question, I don't have a reference but I believe zelman is correct. You void the 222 and file it in sequential order with the rest of your completed 222's.
As for the question, I don't have a reference but I believe zelman is correct. You void the 222 and file it in sequential order with the rest of your completed 222's.
Would you also send the voided copies out or just store all three forms in the pharmacy dea box? Thankfully this has not come up in practice yet for me. Call/email my supervisor would be the answer but not the correct test answer.
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Retain all three copies.
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https://www.deadiversion.usdoj.gov/pubs/manuals/pharm2/pharm_manual.htm#8
As zelman and owle above and also:
Federal jurisdiction:
You retain them unless the DEA Field Office directs you otherwise in writing with a DRO/DLO (and this is part of the Record Control Schedule rule) for at least two years. This also applies if you "lose" them as if you can't say which numbers were lost within a definite range, the PIC personally gets cited for it unless you have something written excusing you from the DEA Field Office. Most SACs are understanding about robberies, but plain stupid losses without knowledge of the numbers usually piss them off. The PIC should always have the range of form serial numbers for the current fiscal year in writing outside of the pharmacy (for a chain, this is usually taken care of by the district warehouse, for a hospital, this is usually the medical records vault). A normal pharmacy should NOT have more than 750 unused forms in the pharmacy at any given time as a best practice (certain states actually have limits placed in their regulations about that as well).
The questions that are usually state-related pertain to if the number of years exceeds the DEA requirement, and the on-site requirement. DEA will cite you if you cannot lay hands on the DEA form within the business day of their request. Certain states (AZ, WI) require true on-site storage on physical premises in the pharmacy of the DEA records unless precleared with the Board on an off-site storage area.
As zelman and owle above and also:
Federal jurisdiction:
You retain them unless the DEA Field Office directs you otherwise in writing with a DRO/DLO (and this is part of the Record Control Schedule rule) for at least two years. This also applies if you "lose" them as if you can't say which numbers were lost within a definite range, the PIC personally gets cited for it unless you have something written excusing you from the DEA Field Office. Most SACs are understanding about robberies, but plain stupid losses without knowledge of the numbers usually piss them off. The PIC should always have the range of form serial numbers for the current fiscal year in writing outside of the pharmacy (for a chain, this is usually taken care of by the district warehouse, for a hospital, this is usually the medical records vault). A normal pharmacy should NOT have more than 750 unused forms in the pharmacy at any given time as a best practice (certain states actually have limits placed in their regulations about that as well).
The questions that are usually state-related pertain to if the number of years exceeds the DEA requirement, and the on-site requirement. DEA will cite you if you cannot lay hands on the DEA form within the business day of their request. Certain states (AZ, WI) require true on-site storage on physical premises in the pharmacy of the DEA records unless precleared with the Board on an off-site storage area.
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