Controlled substance regulations can frequently seem confusing. However, I find that thinking about the main purpose of the regulations can help you determine compliant but practical methods for meeting the requirements.
For recordkeeping, the goal is to document everything that happens to a controlled substance from the time it is ordered until it is administered, dispensed, or disposed of. It is important to check both federal and state regulations to make sure you maintain the required records. Here are some helpful tips to keep in mind.
- If it’s documenting something about controlled substances, save it. Whether it’s a log where people sign when they pick up their pet’s controlled substance, or a cycle count log, if it was important enough to capture in the first place, it’s important enough to keep. Always err on the side of keeping too many records versus not enough.
- Federal law requires keeping controlled substance records for two years. However, Illinois law requires keeping these records for five years.
- Records pertaining to CII medications need to be filed separately from records pertaining to CIII-CV medications. For example, your invoices for CII medications go in one file and your invoices for CIII-CV medications go in a separate file.
- Decide whether you will keep your records for calendar year or fiscal year. Then, every year, pull the previous year’s records from your filing cabinet and put them into a file box (still readily accessible). Label the box with the date after which they can be discarded. This will keep your filing cabinet organized so you can find any recent records you may need to refer to.
When in doubt about controlled substance regulations, check state and federal regulations or reach out to a DEA field office.
This month’s column is from Lauren Forsythe, PharmD, DICVP, FSVHP.
