MPJE: Reverse distributors of controlled substance

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G

Giraffe

Please explain who fills out the DEA form 222, form 41 and who keeps copy 1,2,3 of form 222? Also does the reverse distributor send forms to DEA or both the pharmacy and reverse distributor. I am confused. Please explain. Thanks

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If you look at a copy of form 222, you will see that it actually has three sheets: brown, green, and blue, in that order.

After you fill out form 222, you tear off the blue copy, and you keep that at your pharmacy. Then you send the brown and green copies to the company you're ordering your drugs from (e.g., Amerisource, Cardinal, etc.). The company keeps the brown copy, and after they've sent you all your drugs, they'll send the green copy to the DEA. In general, the company is supposed to send the green copy by the end of the month in which they received your form.

I've never actually had to use a reverse distributor, but if I understand the law correctly, I believe that it's supposed to work in the reverse of what I've described above. In other words, the reverse distributor fills out the 222 form, sends you the brown and green copies, then you send them the drugs to be returned, then you send the green copy to the DEA.

As for form 41, I don't know. I would assume the pharmacy itself fills out the form. At least in retail, you're unlikely to ever see or use form 41. The pharmacies always just send the drugs back to someone else to destroy.
 
Thank for your reply.
As per the Federal Pharmacy Law Book by Reiss and Hall 7th edition(pg.201):
When drugs are sent to the reverse distributor for destruction, the reverse distributor fills out form 41 and sends it to DEA. And the reverse distributor must "issue an official order form DEA222 to the pharmacy".

But it does not make sense, how would the reverse distributor know what drugs the pharmacy wants to get rid of? And so does that mean the pharmacy sends copy 2 of DEA form 222 to DEA and pharmacy keeps copy 1? I have no idea where to find the answers, I have searched online....

Any advise? Thanks
 
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