One of the scariest areas of compliance for veterinarians is use of either their or the clinic’s DEA license. There are very few things that can lead to incarceration at a vet clinic. Falling afoul of the Controlled Substance Act is one of them I get the most questions on. Can a veterinarian, with a proper VCP relationship, prescribe a controlled substance that is filled under the clinic’s DEA account, or do I have to have my own license? That’s the question that I was asked at a recent LEAP event in Macon, Georgia.
Off to the source material! The Practicioner’s Manual, on the DEA’s website, along with the actual controlled substance act, are good places to start. https://www.deadiversion.usdoj.gov/pubs/manuals/pract/pract_manual012508.pdf
The answer, it appears, is that yes, you can use your clinic’s DEA license, if it’s part of the licensed, professional practice of veterinary medicine in Georgia and at that Clinic. You have to track the usage with a very specific record keeping system, and there’s a few other administrative requirements. Page 16 of the manual has some pretty clear instruction. I copied some of it below for your reference.
“Practitioner’s Use of a Hospital’s DEA Registration Number
Practitioners (e.g., intern, resident, staff physician, mid-level practitioner) who are agents or employees of a hospital or other institution may, when acting in the usual course of business or employment, administer, dispense, or prescribe controlled substances under the registration of the hospital or other institution in which they are employed, provided that:
1.The dispensing, administering, or prescribing is in the usual course of
professional practice
2. Practitioners are authorized to do so by the state in which they practice
3.The hospital or institution has verified that the practitioner is permitted to
dispense, administer or prescribe controlled substances within the state
4.The practitioner acts only within the scope of employment in the hospital or
institution
5.The hospital or institution authorizes the practitioner to dispense or prescribe
under its registration and assigns a specific internal code number for each
practitioner so authorized.”
Hopefully this answers the question. Let’s continue to get better together!
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