How to Survive a DEA Inspection Series - Controlled Substances and Hospice Program

Why Should You Attend:

On October 6, 2010 in a Federal Register, DEA issued a Statement of Policy to provide a better understanding of the existing laws and regulations regarding the proper role of a duly authorized agent of a DEA registered individual practitioner about the communication of a controlled substance prescription to a pharmacy. The focus has been on prescriptions written for Schedule II narcotic substances for severe pain of patients in a Hospice Program.

Today’s practitioners and corporations operating a certified Hospice Program will need to familiarize themselves with the stringent federal laws and regulations that are enforced by DEA through their Office of Diversion Control (“Diversion”) for Schedule II narcotic substance administered, dispensed and prescriptions written for patients suffering with pain. This webinar will focus on these laws and regulations.

Areas Covered in the Webinar:

• Review the responsibilities of DEA that are mandated under the Controlled Substances Act to enforce federal laws and DEA regulations on prescribing and dispensing of Schedules II narcotic substances by means of a prescription as part of a treatment plan for pain.
• Discuss the actions taken by DEA against a practitioner and pharmacist for failing to comply with federal laws and DEA regulations when prescribing and dispensing Schedules II narcotic substances to a patient in a Hospice Program.
• Discuss in length the various steps that a practitioner can take to follow the DEA regulations when prescribing Schedules II narcotic substances to a Hospice Program patient and what steps the pharmacist must take to fulfill the prescriptions.
• Discuss the role of the nurse as an authorized agent of the practitioner and their limited role when communicating with pharmacies on behalf of the practitioner.
• Discuss necessary documentation that should be noted in a patient chart to identify the treatment plan to be utilized which may include the prescribing of Schedule II narcotic drugs to relieve the pain suffered by a patient in a certified Hospice Program. Such documentation is required for a practitioner to legitimately prescribe a Schedule II narcotic drug to such patients.

Who Will Benefit:

This webinar will provide assistance to the personnel working for a certified Hospice Program where Schedule II narcotics substances are administered, dispensed, and prescribed for pain for their terminally ill patient. Employees who will benefit include:

• Practitioners
• Medical directors
• Staff nurses
• Senior management
• Program administrators
• Physician assistant
• Pharmacist

Carlos M Aquino
Consultant, PharmaDiversion, LLC

Consultant Carlos M. Aquino brings 36 years of experience on handling illicit and pharmaceutical controlled substances and regulated chemicals. This includes 12 years with the Philadelphia DEA Diversion and 24 years with the Philadelphia Police Department. During the last 10 years, he was assigned to the Philadelphia DEA Task Force as a street supervisor and an undercover agent investigating the distribution of illicit drugs and the diversion of pharmaceutical drugs.

In January 2009, Carlos M. Aquino founded PharmaDiversion, LLC as a compliance consulting firm assisting a DEA registrant, who handle controlled substances and regulated chemicals, with compliance of federal laws and regulations that are enforced by DEA through the Office of Diversion Control. This is done through a “Mock” audit and inspection equivalent to a DEA Diversion on-site inspection. The firm also provides in-service training on various areas pertaining to compliance with federal laws and DEA regulations for handling controlled substances.

Topic Background:

The Drug Enforcement Administration (“DEA”) has been focusing on the prescribing of Schedules II narcotic substances by practitioners caring for their patients in a certified Hospice Program where narcotic drugs are administered, dispensed, and prescribed for the individual patient. Generally, DEA investigations are initiated through an investigation of a pharmacy for Schedule II controlled substance written for pain management. The focus of concern by DEA has been on the legitimacy of prescriptions for narcotic drugs written by the practitioner and the role of the nurse as an authorize agent of the practitioner. DEA regulations place the responsibilities for narcotic prescriptions written for Hospice Program patients not only on the practitioner who wrote the prescription but also on the pharmacist who filled the prescription.

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