As a former veterinary practice owner and hospital administrator, I know it is expensive to order, log, count, and dispense controlled substances. All this is exacerbated further by a multitude of complex regulations and their effect on overhead costs. For example, most primary care practices spend approximately 1.5 hours daily to manage their controlled substances, while most 24-7 specialty and emergency facilities take about four to five hours every day. That’s a fair amount of time considering all that needs to get done in a day. Why does it take so long? Controlled substances regulations are complicated, sometimes contradictory, and confusing. They also pose one of the biggest risks in your practice when they’re not followed properly. Whether at the federal (21 CFR 1300-End) and/or state level, you are required to know and comply with extremely stringent regulations. You also may be subject to controlled substances regulations implemented by your state pharmacy board or your state veterinary board. Just knowing where to look and who to call can mean days of frustrating research. With civil and criminal penalties ranging from a letter of admonition, to monetary citations, to permanent loss of your license, it is imperative you know which regulations you are required to follow to minimize your risk. One of the most important things to remember is that your controlled substances, logs, and corresponding documentation must always be kept secure, current, complete, and accurate. Keeping your supplies stocked is also time-consuming. When ordering your Schedule II controlled substances on the Drug Enforcement Administration’s (DEA’s) Form 222, you must follow the instructions closely, spell each drug correctly, and include the manufacturer’s exact strength and quantity precisely as written on the bottle, all within the confines of very small lines. Any mistake or sign of alteration on the form can cause the distributor to refuse your order.* One way you can save time and decrease frustration is by ordering Schedule II controlled substances electronically through the DEA’s Controlled Substance Ordering System (CSOS) secure network. To do so, registrants must obtain a digital certificate from the DEA. For more information on CSOS, visit deaecom.gov. Schedule III, IV and V controlled substances can be ordered directly from your regular distributor. Price-shopping distributors to determine which offers the lowest price is an important part of inventory control. Finding the lowest prices helps decrease the second-largest expense in your practice, but spending all that time online or on the phone can keep you from seeing patients to increase your revenue! As they say, time is money. But you didn’t go to school to practice paperwork and neither did your technicians! So, what is the solution? Make a profit by managing controlled substances There are numerous ways to not only cover your controlled substances expenses, but make a profit from them! Let’s look at just a few. Because most controlled substances are not price-shopped by clients, but are rather dispensed directly to your patients, it makes good financial sense to consider implementing a controlled substances dispensing fee. This charge would be added to your normal dispensing fee and should cover your overhead expenses related to controlled substances, including the time it takes for your technician to order, store, log, count, measure, and report them. These are costs you do not incur with “legend” drugs such as NSAIDs, so charging the same dispensing fee for both just doesn’t make sense. My experience is your controlled substance dispensing fees should add another $5 to $10 to your existing dispensing fee for each prescription. Increasing your controlled substances dispensing fees within your global fee correctly can go toward upgrading your facility, giving your staff raises, or buying new equipment, for example. I know everyone worries about comparative price-shopping, but the average client does not call around for prices of controlled substances. If a new client calls your clinic and asks your staff whether you have fentanyl (for example) and how much it costs, this might not be the client you want in your practice. If you do not dispense controlled substances to patients, but only administer them directly, you might want to consider increasing your injection fees and/or oral medicating fees to help cover your controlled substances costs and your technician’s time. Inventory is money sitting on your shelves Wasted time is not the only thing costing you money—overstocking can lead to an increase in expired drugs and reverse distributor fees. Think about all the time it takes to do any of the following: get the best price; order, stock, and maintain a lean inventory to avoid costly, last-minute reorders and product expirations; manage your controlled substances to meet compliance standards; and raise prices to stay current with manufacturers’ increases. Have you considered hiring a dedicated inventory manager? It sounds like an expensive proposition, but it’s not when you think about all that needs to be done to manage your controlled substances properly. Using an automated dispensing cabinet In addition to implementing a dispensing fee for controlled substances, you may want to consider an automated dispensing cabinet to save time and money, as well as reduce your regulatory risk. An automated dispensing cabinet can improve security through electronic biometric staff identification. It can also save time by ordering inventory automatically. Further, it can increase compliance by logging your controlled substances, as well as record charges of the drug administered or dispensed directly to the client’s invoice. Problems solved Maintaining your controlled substances and your legend drugs can be difficult and frustrating, but it doesn’t have to be if you train your staff, implement the proper protocols, hire an inventory manager, charge a controlled substance handling fee, and maintain current, complete, and accurate record-keeping. Jan Woods is the professional services and regulatory affairs manager for Cubex, LLC. For further help, information, or to see her speak in person at a veterinary conference near you, contact her at jwoods@cubex.com or www.cubex.com/AskJan. * On Feb. 21, 2019, the Drug Enforcement Administration announced a revised, single sheet, Form 222, which came with its own set of rules and requires practices to adopt new systems to stay compliant with the DEA. For information on the Form 222 and to review the DEA’s frequently asked questions and answers, visit bit.ly/2rpEnQW and bit.ly/2qzzqVZ.
