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DEA Compliance "R.I.S.K." in Dental Medicine
Educational Objectives
After completing this webinar, participants will be able to:
- Record-Keeping: Poor record-keeping is one of the top reasons a DEA registrant gets fined. Why? Because it’s easy to cite. Dental professionals are busy, and when you get busy it’s easy for things to get overlooked, particularly when it comes to maintained controlled substance records. The DEA requires registrants to maintain specific required controlled substance records for the current two-year period on-site at the registered location. Depending on the state you practice in, patient-specific record-keeping requirements are even longer. Ensuring proper documentation and record-keeping is key to maintaining DEA compliance and reducing risk.
- Ineffective Security: DEA registrants have a responsibility to ensure that controlled substances are properly secured from the point of acquisition to final disposition. Still, there are many times throughout the “life cycle” of a controlled substance being used in a practice where security can become lax and at times, nonexistent. From ensuring proper security during the receiving process and properly managing controlled substances waste, to resolving discrepancies in logbooks and accounting for hub loss for liquid controlled substance containers, it is your responsibility to make sure that your controlled substances inventory is continuously secure.
- Storage: The DEA has set forth specific requirements regarding how controlled substances must be stored. These requirements are specific to the manner in which controlled substances are stored based on certain schedules and separation from other non-controlled substance drugs and products as well as the security of the area where they are stored. Secure storage requirements apply to a DEA-registered premise where you practice, and they also apply to any controlled substances that are transported to patient services and care. Failing to comply with DEA storage requirements will not only put you at risk for DEA noncompliance but can also make you an unassuming target for more nefarious things such as drug diversion.
- Knowing Personnel: Do you really know who is working for you? It has become commonplace for dental practices to engage locum tenens professionals to perform a variety of patient services that a traditional practice setting may not offer in-house. Whether it is an anesthetist, oral surgeon, or an employee, it is critical to know who is working for and with you. Preventing diversion and reducing DEA compliance risk starts with the hiring process by ensuring that any individual who is being authorized to work with controlled substances has undergone proper vetting processes.
Abstract
If the DEA showed up tomorrow, how sure are you that your practice would pass an inspection? When you accept the privilege of having a DEA registration, you automatically give the DEA permission to enter and inspect your registered premises at any time to check that DEA storage and record-keeping requirements are being adhered to. The DEA is not required to provide notice prior to conducting an inspection; and, if you are found to be “non-compliant,” $15,691 is the maximum fine per infraction for which the DEA has the authority to cite and fine the registrant of record.
Averting DEA compliance risk requires ongoing due diligence and proactive measures to help prevent controlled substance issues from arising; and, if and when they do, to ensure issues are quickly identified and properly addressed before they escalate. While there is no “quick fix” to DEA compliance, there are ways to make required processes easier.
Additional Information
Author Bio
Dr. Michael Block
Dr. Block graduated from the University of Rochester in 1975, attaining both a BA in biology and a BS in biomedical engineering. He completed his dental training at the Harvard School of Dental Medicine in 1979, receiving his DMD. cum laude in a special field. He completed his residency program in oral and maxillofacial surgery at the LSU School of Dentistry in 1983. He remained at the LSU School of Dentistry and achieved the academic rank of professor in the Department of Oral and Maxillofacial Surgery. Currently he is in private practice.
Dr. Block is the editor-in-chief of five textbooks on dental implants, Endosseous Implants for Maxillofacial Reconstruction, Implants in Dentistry, Color Atlas of Dental Implant Surgery: (the 4th edition was published in 2015). He is past president of the Academy of Osseointegration, and has been program chairman for three of their annual programs. Dr. Block has served on the American Association of Oral and Maxillofacial Surgeons (AAOMS) Committee on Continuing Education as chairman of the subcommittee on dental implants. Dr. Block has been an examiner for the American Board of Oral and Maxillofacial Surgery. He is a section editor on dental implants for the Journal of Oral and Maxillofacial Surgery.
Dr. Block is particularly interested in the translation of technology for efficient and predictable reconstruction of the jaw to provide ideal bone for implant placement and esthetic replacement of missing teeth, the use of multiple techniques and implants to reconstruct significant atrophic conditions, and interceptive strategies for rehabilitating extraction sites with implant restorations.
Hobbies and interests include golf, skiing, road cycling, nutrition, science fiction, and computer technology.
Kelley Detweiler
Kelley Detweiler is an internationally recognized author and DEA regulatory compliance expert who works with companies that handle DEA controlled substances and listed chemicals (drug “precursors”). Kelley actively consults on complex matters involving controlled substances and listed chemical issues for global corporations and companies operating in the public, private, and government sectors. Her in-depth knowledge on how to navigate regulated substances and materials from the point of manufacturing throughout the entire supply chain has provided her with the opportunity to speak on international platforms, including the United Nations, and to serve as a subject matter expert for Bloomberg News.
Kelley coauthored “Safeguarding Controlled Substances” published in 2021, and currently authors the “Let’s Talk Drugs” national column hosted by the NAVC suite of publications.
Disclosures
Commercial Disclosure
This free Dental Learning presentation is made possible through the continued support of . Dr. Michael Block and Kelley Detweiler are consultant and/or speaker for the following companies and/or organizations: Dental Learning, . Dr. Michael Block and Kelley Detweiler may receive an honorarium as compensation from the CE Supporter of this presentation and/or from Dental Learning for the time involved in preparing and delivering this online presentation.
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