Surviving a DEA Inspection by a Hospice Program

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The Drug Enforcement Administration (DEA) has been focusing on the prescribing of Schedules II narcotic substances by practitioners caring for their patients in a certified Hospice Program where narcotic drugs are prescribed for the individual patient.

The focus of concern by DEA has been on the legitimacy of prescriptions for narcotic drugs written by the practitioner and the role of the nurse as a authorize agent of the practitioner. DEA regulations place the responsibilities for narcotic prescriptions written for Hospice Program patients not only on the practitioner who wrote the prescription but also on the pharmacist who filled the prescription.

On October 6, 2010 in a Federal Register, DEA issued a Statement of Policy to provide a better understanding of the existing laws and regulations regarding the proper role of a duly authorized agent of a DEA registered individual practitioner in connection with the communication of a controlled substance prescription to a pharmacy. The focus has been on prescriptions written for Schedule II narcotic substances for severe pain of patients in a Hospice Program.

Today's practitioners and corporations operating a certified Hospice Program will need to familiarize themselves with the stringent federal laws and regulations that are enforced by DEA through their Office of Diversion Control (Diversion) for Schedule II narcotic substance prescriptions written for patients suffering with pain. Generally, the focus of any DEA Diversion investigation is the legitimate medical purpose for the prescription. The initial targets are the practitioner who wrote the prescription and the pharmacy that fulfilled the prescription. In Hospice Programs, the focus of concern is also the role of a nurse in communicating with pharmacists as an authorized agent of the practitioner.

Areas Covered in the Session: Class participants will familiarize themselves with federal laws and DEA regulations requirements for practitioners prescribing Schedules II controlled substances for a patient in a certified Hospice Program and the role of the nurse as an authorized agent of the practitioner. The presentation will:
Review the responsibilities of DEA that are mandated under the Controlled Substances Act to enforce federal laws and DEA regulations on prescribing and dispensing of Schedules II narcotic substances by means of a prescription as part of a treatment plan for pain.
Discuss the actions taken by DEA against a practitioner and pharmacist for failing to comply with federal laws and DEA regulations when prescribing and dispensing Schedules II narcotic substances to a patient in a Hospice Program.
Discuss in length the various steps that a practitioner can take in order to be in compliance with the DEA regulations when prescribing Schedules II narcotic substances to a Hospice Program patient and what steps the pharmacist must take in order to fulfill the prescriptions.
Discuss the role of the nurse as an authorized agent of the practitioner and their limited role when communicating with pharmacies on behalf of the practitioner.
Discuss necessary documentation that should be noted in a patient chart to identify the treatment plan to be utilized which may include the prescribing of Schedule II narcotic drugs in order to relieve the pain suffered by a patient in a certified Hospice Program. Such documentation is required in order for a practitioner to legitimately prescribe a Schedule II narcotic drug to such patients.
Who Will Benefit: Participants of this presentation are practitioners working for a certified Hospice Program where Schedule II narcotics substances are prescribed for pain for their terminally ill patient. Other participants that can benefit from the presentation include: program administrators who are responsible for the everyday operation of the certified Hospice Program, a nurse working for a certified Hospice Program, physician assistant, nurse practitioners and the pharmacist who fulfill Schedule II narcotic substance prescriptions to a certified Hospice Program for terminally ill patients as directed by the practitioner.