for EMS Our story at Katy Fire Dept Overview Our Story What went wrong DEA 222s Invoices Distribution Inventory Education History 20 years of EMS we have never had a DEA auditInvestigation ID: 650021
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Slide1
DEA Do’s & Don'ts for EMS
Our story at
Katy
Fire Dept.Slide2
OverviewOur Story
What went wrong
DEA 222’s
Invoices
Distribution
Inventory
EducationSlide3
History
20+ years of EMS we have never had a DEA audit/Investigation
1 Medical Director
Numerous EMS Directors
All certifications were up to date (DEA, DPS, DSHS or TX Dept. Of Health)
Protocols regularly reviewed and updated
CCTV with recording and Cyber keys in place for control measures
Log books in place Slide4
What went wrong
Protocol change to phase out Valium and add Ativan
(Diazepam) (Lorazepam)
Surplus Valium in stock
Valium should have been returned to vendor or destroyedSlide5
What went wrong
No
one questioned the
Boss
The boss knew better than anyone
The boss educated staff
The boss wouldn’t do wrongSlide6
What else did we find?Appropriate boxes must be filled out & legible.
Each infraction or missing 222 $10,000Slide7
Copy 3 will be for receiving
Packages received and date received
must be completedSlide8
Invoices
Can be kept in two places
On site
City Hall/finance/records
Letter must be on file with the DEA listing the address and intent to keep invoices at a different address than where scheduled drug are delivered
and stored.
Keep invoices, packing slips, and 222 forms together and keep for 2 years
Invoices & Packing slips are NOT the same!!!
Packing slips should be signed and dated to account for arriving narcotics.
Each missing invoice is $10,000Slide9
Distribution
Agencies with multiple stations:
Cannot distribute from a central station without licensure
Cannot distribute narcotics to an ambulance then post the ambulance (anywhere) for a majority of the workday
Each station must be on file with DEA
Drugs must be delivered to that address for supply, distribution, and usage.
Power of Attorney
You must have a power of attorney on file to purchase and distribute narcotic on behalf of the medical director.
1 POA for purchasing
1 POA for distributionSlide10
Biennial Inventory
Biennial
Inventory (2yrs) of
scheduled drugs must be completed and on
file!Slide11
Education
Educate your personnel
Diversion education should be part of new hire indoctrination
Continuing education on diversion should be a part of your training program
Once found, you have 24 hours to report missing (LOSS or THEFT) narcotics to the DEA!!! Form 106 or call to DEA