Narcotics Compliance

Sooner or later, your agency's narcotics usage and inventory will be audited by the DEA. You must establish and enforce your compliance program now, in preparation for that day.

They can fine you $2,000.00 for each dose you cannot account for, and restrict or altogether revoke your DEA number.


Configuring Your Medications List

Using the Medications List under Supervisor Home, make sure all of your narcotics are in the list and are flagged as ☑ Narcotic.

Also consider setting the ☑ Crew must record a dose ID number from the vial flag on all medications that you are required to track. When this flag is set, the PCR will prompt crew members to type in the dose identification number from the vial... even if the dose was wasted.

Of course you will need to verify that your reportable doses actually have unique ID numbers stamped on the vials. If they don't, then AngelTrack strongly recommends you switch suppliers, choosing one that offers individually trackable narcotics doses.

Two Different Approaches to Issuing Narcotics

You company is required to know where all of its narcotics doses are at any given time... and yet you must allow crews to carry narcotics around with them during the day. There are two approaches to solving this problem:

Approach 1: Daily Checkout / Checkin

In the morning, a supervisor issues a narcotics pouch to each crew, inspecting the contents and collecting signatures from the recipients. Each evening, the pouches are returned, with another inspection and signoff.

This is a strong system but requires there to be a supervisor at the station every morning and evening without fail. Therefore it is not practical for smaller EMS operations, whose supervisors spend most of their time aboard an ambulance.

Approach 2: Lockbox Assignment

Lockbox with sleeve When hired, paramedics are issued a small padded lockbox containing two doses of each reportable narcotic, and the key. When off shift, the paramedic stores his lockbox in a locker or locking trays provided for this purpose at the station. At any time, the paramedic must answer for the box's contents.

This system dispenses with the daily checkin/checkout, which means it can sustain itself even when no supervisors are present at the station. There will be an occasional hassle when someone loses their key or forgets their combination, but other than that it is a low-maintenance alternative. It does require the company to purchase additional doses, because every paramedic on the payroll must have a full set of narcotics in their name, plus enough spare doses to restock any that are used.

There are lockbox systems available that include locking trays and sleeves, for securely storing the lockboxes on the wall at the station. Additional trays/sleeves can be purchased and installed inside the ambulances, so that the paramedic can securely leave their lockbox in the vehicle during their shift. Just buy an extra sleeve for each vehicle, and bolt it in the back near the stretcher mount.

Whichever approach you choose, commit to it

Whichever approach you choose, commit to it. Demand your supervisors and crews take it seriously. Hand down harsh disciplinary measures when employees are found to be cutting corners.

If and when the DEA comes knocking, you must account for every single dose, going as far back in time as they see fit. Each unaccounted-for dose carries a fine up to $2000.00. They will also review your tracking procedure, and they might suspend your DEA number if they are not satisfied that your employees are committed to that procedure. It could be a serious blow to your operation.

Clear it with your legal team first

This is not legal advice. Narcotics laws vary by state, and the attitudes of DEA auditors vary by region. Submit your proposed tracking system and associated policies to your legal team before putting it in practice.

Crew Responsibilities

Crews are responsible for keeping track of their lockbox or pouch during their shift. At shift end, crews will sign the pouch back in or lock it up, depending on which of the above approaches your company took. In any case, do not permit any narcotics to remain on board an ambulance once it is out of service; during the night, all narcotics should be locked back up in the station except for those in the possession of your overnight crews. Vagrants know that ambulances carry narcotics, and they will not hesitate to rifle through your parked trucks to find some. Also, once your employees become aware that narcotics are left in unattended ambulances, one of them might seize that opportunity for diversion. It could then be days or weeks before the theft is noticed.

Crews are also responsible for creating the appropriate medication records in AngelTrack's PCR whenever narcotics are used or wasted. No matter what happened to that dose, it must be recorded in AngelTrack, period. When a crew signs their narcotics back in, if a dose is missing, the crew should be able to open the PCR and show the medication record they created for the consumption of that dose.

Supervisor Responsibilities

Supervisors are responsible for developing and administering the system of boxes or pouches that are issued to crews. That means issuing keys to storage lockers or racks, and keeping track of who is assigned which lockbox or locker.

Supervisors also maintain the change-of-hands log, that documents each time a box/pouch changes hands, attesting its contents.

Whenever a dose is used, supervisors are responsible for restocking the dose, and notating the station's narcotics inventory to show that the dose was issued to a particular box/pouch. Before issuing the replacement dose, the supervisor should demand to see the AngelTrack PCR record showing the disposition of the original dose -- be it administered or be it wasted. The supervisor can either inspect the PCR record on the crew's tablet, or they can use the Medication Usage Report on their own tablet to see the dose record.


Surviving the Audit

With the aforementioned policy in place, you are ready for the audit.

Part 1: Showing your procedures

The first half of the audit is an examination of your compliance policy, including an informal assessment of how well the policy is practiced. The auditors want to see that your organization cares about this stuff. They want to see that your organization maintains awareness of all narcotics in its possession, from arrival in the mail all the way through administration to the patient. They want to see that employees are aware that compliance procedures are in place and so there is no opportunity to pilfer narcotics.

This is when you will get to show off your locking narcotics boxes, and your checkoff log that documents each time a locking box (or its key) changed hands. Your log will show that a third person inspected the box each time it was passed from one person to another. It is not a foolproof system, but it is a good system and will show them that you are making the effort. If the auditors see you making the effort, then they will probably be inclined to cut you some slack on those occasions where the system failed.

Part 2: Accounting for each dose

The second half of an audit is a dose accounting. The auditors will already have a list of all narcotics that your company purchased (your supplier reports all narcotics purchases directly to the DEA). They will ask to see documentation of where each dose was administered or wasted. This is where AngelTrack comes to the rescue. The Medication Usage Detail report was specifically designed to satisfy this part of a DEA audit.

The report allows you to specify any medication and any date range. It will show all doses given and wasted during that date range, by all employees or by a specific employee. It also shows dose/vial identification numbers, if you have elected to record those numbers. DEA auditors usually do not insist on tracking at that level of granularity, but if you show that you can in fact track each numbered vial, all the better.

The report also includes links to the printed run reports of all cases where narcotics were used or wasted. You can impress the auditor by downloading all the report .PDFs and burning them to a CD for him.

The Medication Usage Detail Report is accessed by first visiting the Medication Usage Report under Supervisor Home. Click on any medication in that report to dive down to the detail report.

You can also show the auditors the Narcotics Usage Report under HR Home, which looks for patterns of use and waste across all crews. The report is designed to identify crews who use or waste an unusually large amount of narcotics. You can show the report to the auditors in order to demonstrate that your company maintains awareness of its narcotics usage rates, with an eye for patterns indicating diversion.

Please Take This Seriously

If you've never been hit by a DEA audit, this lengthy help document probably seems like a lot of palaver.

Force yourself to take it seriously. An audit could happen at any time... and not only could that result in stiff fines, you might even lose your DEA number. Without a DEA number, you can't obtain the medicines you need to deliver ALS and MICU service. You could get busted back to BLS while you appeal your suspension, and that can cost you some precious contracts.

Set up the tracking systems now, and ride your supervisors and crews now, as an insurance policy that protects your operation's future.

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