39 Tablets Short, a Departed Signer, and a Shoebox of Expired Oxycodone
You have just taken over as pharmacist-in-charge. The last biennial inventory was taken 27 months ago. Counting oxycodone 15 mg, you find 312 tablets on the shelf against 351 expected from the records. Purchases have been made through CSOS electronic orders, but two paper DEA Form 222 orders in the file were signed by a pharmacist who left four months ago. The pharmacy also holds a shoebox of expired Schedule II tablets that the owner wants to "mail back to the wholesaler," and a wholesaler representative has offered to take them "with no paperwork." No police report has been filed.
1. What are the inventory obligations, and how do you handle the 39-tablet discrepancy?
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Inventory obligations. A biennial inventory must be taken every two years, on a date the registrant selects, and must be exact for Schedule II. It is kept with the required signature and date/time, and records are retained per federal and Alabama Board requirements. This pharmacy is nine months overdue - take a complete, exact count inventory now and document that it is a corrective inventory.
Discrepancy.
- Reconcile before alleging loss. Recheck the count, invoices, dispensing records, partial fills, returns, and any transfers. Many apparent shortages are bookkeeping errors.
- If a real loss remains: it is a significant loss of a Schedule II substance and requires a DEA Form 106, with copies retained, plus notification as required to the Alabama Board of Pharmacy.
- Investigate access - who had keys, who performed counts, whether diversion occurred. Do not accuse without evidence, but do not paper over it either.
- Correct the perpetual records only after the investigation is documented.
2. What is the problem with the paper Form 222 orders and the CSOS authority?
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Authority to order did not expire gracefully - it ended when the signer left.
- Paper DEA Form 222 can be executed only by a person named on the registration or holding a valid power of attorney. Orders signed by a departed pharmacist after her departure are not validly executed, and any continuing power of attorney granted to her should have been revoked in writing on her last day.
- For CSOS, review the power of attorney records in the system and revoke the departed pharmacist's credentials immediately; confirm no one else retains ordering rights who should not.
- Audit the orders received under those signatures: confirm the drugs were actually received into inventory and match invoices. If product entered the premises on an invalid order, that feeds directly into the shortage investigation above.
- Going forward, maintain a current, signed, dated list of persons authorized to order Schedule II substances and review it whenever staffing changes.
3. How should the expired Schedule II tablets be disposed of, and what do you tell the owner and the wholesaler representative?
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"No paperwork" is not an option, and neither is putting controlled substances in the mail.
A Schedule II substance moving from one registrant to another requires a DEA Form 222 (or CSOS equivalent). A reverse distributor or the supplier issues the 222 to the pharmacy; the pharmacy transfers against it and retains its records. Handing the bottle to a representative with nothing signed leaves the pharmacy unable to account for the drug and creates an unexplained loss on the next inventory.
Acceptable routes:
- Transfer to a DEA-registered reverse distributor against a 222.
- On-site destruction with the required DEA destruction record and witnesses, per current DEA rules.
- Use of an authorized collection receptacle where permitted - not ordinary mail, and not a wholesaler's trunk.
Say to the owner: the paperwork exists to protect her registration. Say to the representative: no transfer without a 222. Document the transfer, quantities, and dates, and keep the records for the required retention period.