I am leaving my current job. What should I do with versed/fentanyl that were ordered for procedural IV sedation at the clinic under my DEA license? Dispose of them with nursing witnesses? Somehow sign over to the rest of the doctors in the practice? Just walk away? Thoughts would be appreciated?
Leaving current job
- Thread starter ArkAngel
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Did you pay for it? If not, it's not your property so just walk away.
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best is if you call a DEA agent and ask them to come by and pick up the meds to be disposed of.
technically, if the office is still open, i believe you can document somewhere that you "signed them over" to another DEA registrant in the office....
technically, if the office is still open, i believe you can document somewhere that you "signed them over" to another DEA registrant in the office....
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Only if you're a partner. If an employee of mine destroyed a bunch of my stuff on the way out I'd take it out of their last paycheck
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if he ordered and got the meds under his DEA - how are they your meds? only he can prescribe them...
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In a multi doc practice, only one DEA is linked to vendor account for purchasing for the practice. If he's an employee he shouldn't have let them use his DEA. If the meds are purchased through the practice's account, paid for by the practice, they belong to the practice.
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That sounds like the "right" reasonable thing to me, too. However, I don't like that argument against a federal prosecutor/special agent in charge trying to further their career by vilifying a physician pouring these dangerous drugs into our streets.
I don't have real life advice for the OP, but I too would be putting in a bit of extra CYA in this situation.
I guess its just the fear of having controlled substances under my license at a practice that I now have no involvement with. What if the medications go "missing"? I just worry about law enforcement coming knocking at my door or asking questions in the future.
OK thanks for the response. I guess in this situation if the controlled meds were ordered under my license, they still technically belong to the practice so one would just walk away? As others have said I am just trying to CYA as much as possible. I have also not heard of "signing over" controlled substances to other doctors so not sure what to do in this situation.
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I don't see how you'd be liable if you are no longer employed and the meds are not in your possession or control.
Lesson learned though--don't let someone else use your DEA number to buy their drugs.
Lesson learned though--don't let someone else use your DEA number to buy their drugs.
Analgesia108
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I would list and account for all unused controlled substances & have the employer sign as a witness as you dispose them safely
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Unless you record the lot number of every vial you purchased and then subsequently used, how would anyone know the difference between “your” fentanyl and “their” fentanyl. Also it sounds like it was your license but not your money used to purchase it? You don’t own it then. If you decide to waste it you have essentially destroyed supplies belonging to the clinic and that is theft. I’m thinking theft of a controlled substance is a lot more serious than what you’re worried about. Just like if your name was used to order omnipaque, you don’t get to take those vials with you on your way out.
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you dont own it but you have some responsibility for it, unlike non controlled substances. he cannot be cavalier about the Schedule II drugs.
if someone in the office gives the medication and there is a complication or it is stolen, then the DEA registrant may be implicated.
you guys may not remember, but in the old days, we used to have prescriptions with our DEA printed on it.
if we lost that prescription pad, and someone used them illegally and wrote prescriptions on those scripts, we potentially still had some liability.
i personally saw a DEA agent come to the ER and interrogate one of my colleagues to confirm that he in fact did not write a prescription for "Mopheen 1 pound". yes, it was before some of you guys got in to med school...
if someone in the office gives the medication and there is a complication or it is stolen, then the DEA registrant may be implicated.
you guys may not remember, but in the old days, we used to have prescriptions with our DEA printed on it.
if we lost that prescription pad, and someone used them illegally and wrote prescriptions on those scripts, we potentially still had some liability.
i personally saw a DEA agent come to the ER and interrogate one of my colleagues to confirm that he in fact did not write a prescription for "Mopheen 1 pound". yes, it was before some of you guys got in to med school...
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Unless you are leaving on less than ideal terms, I'd think you could draw up a simple statement indicating X was purchased under your license, lot #... and it has been retained by the practice signed by you and a responsible party (doc or practice manager). Not a fail safe, but an understanding of possession. If they aren't reasonable, you could claim they stole it.
Just a couple years ago, an employee stole my partner's Rx pad with DEA number/triplicate. He was writing #60 oxy for himself q5 days. It went on almost a year until a different pharmacist was filling in, who called the office to confirm the rx. It got weird real quick. I don't think he was using much (or any) of it, but no felony for sale/distribution/etc.
The doc could tell it wasn't his signature, but it otherwise looked just like a normal rx (ignoring the q5 day pattern in perpetuity.)
Just a couple years ago, an employee stole my partner's Rx pad with DEA number/triplicate. He was writing #60 oxy for himself q5 days. It went on almost a year until a different pharmacist was filling in, who called the office to confirm the rx. It got weird real quick. I don't think he was using much (or any) of it, but no felony for sale/distribution/etc.
The doc could tell it wasn't his signature, but it otherwise looked just like a normal rx (ignoring the q5 day pattern in perpetuity.)
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All controlled drugs have to be accounted for on a DEA form 222 which tracks it from the vendor to the purchaser. Surprised all these responses and no one mentioning this. Does no one else here order controlled drugs? The DEA is very clear about how to handle controlled drugs and spells out what to do on the 222 form. To the OP, if you ordered the drugs with your DEA number then they are yours and you have to dispose of them or keep them in your possession. Your DEA form 222 is tied to you. If they were bought by the practice then they are accounted for on their 222 and you don’t have to do anything.
I recently had to deal with all this when setting up an ASC. It was an existing license which merged with another entity, both had controlled drugs and two different form 222.
I recently had to deal with all this when setting up an ASC. It was an existing license which merged with another entity, both had controlled drugs and two different form 222.
