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DEA Form 222
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Order form for CI and CII substances.
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DEA Form 106
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Report Theft or Loss - Notify DEA and police of significant loss within 1 business day.
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DEA Form 224
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Registration required for all pharmacies that dispense controlled substances.
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How often does a pharmacy renew their 224?
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Every 3 years
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DEA form 224a
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Renewal application - every 3 years
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DEA Form 224b
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renewal for chain pharmacy registration- every 3 years
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5 Classes of Drugs frequently abused
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1. Opioids
2. Depressants
3. Hallucinogens
4. Stimulants
5. Anabolic Steroids
2. Depressants
3. Hallucinogens
4. Stimulants
5. Anabolic Steroids
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Motives to divert Drugs
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-public health
-social welfare
-economic burden
-social welfare
-economic burden
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Methamphetamine act of 2005
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-max of 3.6gm/day
-max of 9gm/30 day period
-max of 9gm/30 day period
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Societal Impact of Controlled substance diversion
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-Violent and property crime
-higher health insurance premiums
-higher health insurance premiums
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Transfer of business (DEA policy)
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Must notify the DEA 14 days prior to transfer from one pharmacy registrant to another, either in person or by certified mail.
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What must be submitted to the DEA for the transfer of business?
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-Name, address, registration number and authorized business activity of the registrant discontinuing the business (registrant->transferer)
-same info but registrant->transferee
-whether the business will be at the same location or moved
-the date on which the transfer of controlled substances will occur
-same info but registrant->transferee
-whether the business will be at the same location or moved
-the date on which the transfer of controlled substances will occur
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Transfer of business- Class II
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The receiving registrant must complete a DEA 222 transferring of drugs
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Transfer of business- Class III-V
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The receiving registrant must be done in writing, showing drug name, dose, strength, quantity and the date transferred.
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Initial Inventory
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It does NOT have to be turned in to the DEA, but MUST be kept on file.
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Initial Inventory upon being granted DEA registration
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Registrant must take an actual physical count of all controlled substances
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Diversion Patterns
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-work additional shifts
-missing DEA 222 forms
-discrepancies
-change in personality/work performance
-inconsistent prescribing habits
-higher than average controlled substance waste/removals
-missing DEA 222 forms
-discrepancies
-change in personality/work performance
-inconsistent prescribing habits
-higher than average controlled substance waste/removals
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Outdated Controlled Substances
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Compare perpetual inventory VS reverse distributor
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Medication Waste
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-audit waste quantities
-require a witness for all controlled Substance waste
-require documentation of all controlled waste
-use of drug disposal systems
-require a witness for all controlled Substance waste
-require documentation of all controlled waste
-use of drug disposal systems
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Dispensing
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-use of unit of dose packaging
-ADC compounding function
-inspection of prepared products for tampering
-limit number and type of controlled substance stored in patient care areas
-sending CS to a patient care area or ADC
-ADC compounding function
-inspection of prepared products for tampering
-limit number and type of controlled substance stored in patient care areas
-sending CS to a patient care area or ADC
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Drug Diversion
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deliberate redirecting of a drug from a patient or facility to the employee for personal use
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Physical signs of potential diversion
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-frequent runny nose
-slurred speech
-sleepiness
-shakiness/tremors
-watery eyes/constricted or dilated pupils
-progressive Deterioration in personal appearance or hygiene
-slurred speech
-sleepiness
-shakiness/tremors
-watery eyes/constricted or dilated pupils
-progressive Deterioration in personal appearance or hygiene
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Areas most vulnerable to diversion
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Pharmacy-secluded areas with unsecured controlled substances
-compounding and receiving areas
-compounding and receiving areas
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Procedural Areas vulnerable to diversion
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-open access to anesthesia and pain medications
-limited pharmacist review
-ability to pull medications without prior order
-limited pharmacist review
-ability to pull medications without prior order
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Removal from Safe or ADCs
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-limited oversight
-potential for tampering prior to preparation return or waste
-potential for substances while compounding or prepacking
-potential for tampering prior to preparation return or waste
-potential for substances while compounding or prepacking
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DEA form 41
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Destroying outdated expired controls
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DEA check formula
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1st- Calc (+ 1, 3, 5)
2nd- Calc (+2, 4, 6 x 2)
3rd- add part one and part two
4th- the right most digit is check number
2nd- Calc (+2, 4, 6 x 2)
3rd- add part one and part two
4th- the right most digit is check number
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What letter does the reverse distributor start with?
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P or R
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DEA Form 107
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Theft or loss of listed chemical