Access to Controlled Substances
Associate IndeVets carry federal DEA licenses along with any applicable controlled substances licenses needed in the states where they are licensed. Associate IndeVets do not have their own prescription pads. This protects their privacy and reduces the risk of fraud. Associate IndeVets require access to controlled substances during their shifts
- Please provide access instructions (code, key, other doctor in the building) prior to the shift by emailing or upon arrival (ideal) to the Associate IndeVet at the beginning of a shift.
- If a Partner Hospital does not have controlled substances, or if an Associate IndeVet is not given access to controlled substances, they will need to be restricted in their appointments to only well visits or stable sick pets.
- When there is no access to controlled substances, the Associate IndeVet will refer patients that are emergent, need sedation, need euthanasia, are seizing and/or coughing.
- Stable sick pets include skin issues, ear issues, and mild gastroenteritis, among others.
Minimum Requirements for Handling of Controlled Substances
The following are minimum requirements for the handling of controlled substances by an Associate IndeVet:
- Controlled substance ordering and auditing
- DEA regulations require an active, in-state, hospital-specific or DEA-licensed veterinarian to be present at a hospital.
- Because of this, Associate IndeVets are not permitted to hold the DEA license for Partner Hospitals.
- For questions regarding this policy, please email
[email protected].
- Access to controlled substances (federal guidelines)
- All controlled substances (tablet, liquid, injectable, or patch) should be locked up during an Associate IndeVet’s shift according to DEA regulations.
- Many states require controlled substances to be double locked, meaning in a locked safe and behind a locked cabinet or door.
- Controlled substances should be locked behind a door after hours when a Partner Hospital is closed.
- Controlled substances that need refrigeration should be locked in a safe that is bolted to the inside of the refrigerator.
- Expired controlled substances should not be kept with unexpired controlled substances.
- Recording and documenting controlled substances
- Federal law requires that controlled substances are appropriately logged with the following information:
- Received and opened date
- Date the substance was dispensed and administered
- Name of client and patient
- Address of client
- Client/chart number
- Species of the patient
- Amount dispensed
- Current running total amount or balance
- Signatures of doctor and witness
- Schedule II controlled substances
- Associate IndeVets can’t write prescriptions for Schedule II controlled substances since federal law mandates that Schedule II prescriptions be handwritten on a prescription pad.
- Some states allow Schedule II prescriptions to be typed and printed directly from practice software. In such instances, Associate IndeVets can prescribe Schedule II medications if necessary.
- Schedule III-IV controlled substances
- Associate IndeVets can call in non-Schedule II controlled substances directly to pharmacies if they have a valid VCPR with the patient.
- Controlled substance refills
- To protect against controlled substance diversion and to adhere to state practice acts, Associate IndeVets will not refill controlled substances to an outside pharmacy that were prescribed by another veterinarian.
