COVID-19 & Your Controlled Substances

The COVID-19 Coronavirus has led to a significant amount of confusion concerning the management of controlled substances amidst a national pandemic. We have received multiple questions concerning how to properly manage controlled substance inventory during closures and/or layoffs.  Below is a list of options in the event that your facility is forced to close and/or must lay off key personnel.

Option 1

The individual DEA Registrant whose DEA registration number was used to purchase the controlled substances owns those controlled substances, regardless of who paid the invoice.  In the event that the DEA Registrant is laid off, that individual should take the controlled substances and store them in a DEA-compliant storage container at his/her residence. The DEA Registrant should also immediately login to the DEA Diversion Website and modify their DEA registration to reflect the “new” registered address. The DEA Registrant must also contact the local DEA Office of Diversion Control and advise them of the temporary emergency storage due to the COVID-19 pandemic.

Option 2

The second option would be to transfer all of the controlled substances to another DEA Registrant; however, the probability of another doctor willing to take the controlled substances during a pandemic is low.

Option 3

A third option is to send all of the controlled substances to a registered reverse distributor for destruction. 

DEA E-Mail Updates

The DEA has created a link for individuals to register for updates and guidance via e-mail during this time. We encourage you, and all of your staff, to register your e-mail addresses. TITAN Group will also be sending out information as it is released concerning DEA updates and any new regulatory guidance that is issued.

Register For Updates:

To register for DEA e-mail updates, visit one of the following links:

  1. DEA COVID-19 Information page
  2. https://public.govdelivery.com/accounts/USDOJDEADCD/subscriber/new

TITAN Support & COVID-19

In times of crisis, even the best plans can “go out the window”. This is when you must be extra proactive concerning the oversight of controlled substances.  When the supply chain is cut off, theft of necessary medical products that can be used on humans are at increased risk for theft.

During this National Emergency, TITAN Group will continue to work with our industry partners, DEA Registrants, and their representative associations to assure that controlled substances in the veterinary community continue to be managed in a safe and secure manner.  In addition to offering Continuing Compliance Support, TITAN has also launched a new DEA Compliance Analysis service to assist veterinary professionals with controlled substance compliance in a completely remote capacity. To learn more, please e-mail info@titangroupdea.com or contact our Chief Operating Officer, Kelley Detweiler, at 973-433-3050.

If you feel that you have experienced a controlled substance theft and/or loss, or have identified diversion activities in your facility, a Remote Inspection can provide the same benefit as onsite services. The TITAN Remote Inspection is a secure, cost-effective tool that allows DEA experts to assess your current policies, procedures and physical infrastructure to ensure that your controlled substances remain safe and secure.

As our nation continues to battle the COVID-19 pandemic, we are here to support you and your team with questions concerning the continued safeguarding of controlled substance inventory. Our thoughts and prayers are with you through these trying times.

Regards,

 

Jack Teitelman

Founder & CEO

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