There are a couple items surrounding the ordering of CII medications that would be worth your time to confirm compliance within your organization. This applies to ordering with paper 222 forms and CSOS.
Does everyone ordering CIIs have a Power of Attorney (POA) granted by the Registrant on file? Confirm these are on file and can be produced if the DEA were to walk in. All staff signing paper 222s or ordering through CSOS need a POA. Read more about these regulations here. If an organization has only one person with a POA on file, that would be an immediate red flag to the DEA because no pharmacist is going to be available to sign for CIIs 7 days a week, 365 days a year if needed. This would indicate others are ordering when not appropriate or that CSOS log on information is being shared which is prohibited.
In a hospital, the Registrant is usually someone within the Leadership Team such as the CEO or CNO. Don’t forget to revoke the POA when someone leaves. Only the Registrant’s signature is required for revoking. If the Registrant leaves the organization, a new POA is not required because the Registrant signed on behalf of the organization. The organization would just move forward with all new POAs or revocations utilizing a new Registrant.
The second reminder is that the 222 form must accompany the invoice and confirmation needs to be done upon receipt by a pharmacist that the packing slip matches the 222 and invoice. If using CSOS, print a copy of the CSOS form. This will act as the paper 222 and the receiving pharmacist should use it to confirm accuracy of the shipment received (packing slip and invoice) and then file it someplace accessible should it be requested by the DEA. Don’t forget to sign the paperwork indicating who received in the order. Read more about the regulations surrounding ordering CIIs here.
It takes less time to do it right than to explain why you did it wrong– Henry Wadsworth Longfellow
