Don’t get caught in the crossfire.

On October 1, 2019, the Drug Enforcement Administration (DEA) released its 2020 fiscal year work plan to its diversion investigators. The plan outlines increased enforcement efforts and administrative resources dedicated to the identification and investigation of prescribers (including veterinarians) that are dispensing disproportionately large amounts of controlled substances.

This likely means increased DEA audits and inspections throughout the veterinary community in the coming year.

With a growing number of veterinarians and veterinary practices being charged with DEA noncompliance and failure to prevent drug diversion, veterinarians have become a target for DEA unannounced inspections, administrative warrants, and, in worst case scenarios, search warrants.

These investigations begin with DEA agents reviewing veterinarian purchase patterns through their Automation of Reports and Consolidated Orders System database (ARCOS), which automatically tracks the path of every opioid pain pill sold in the US from point of manufacture to point of sale or distribution. The DEA uses the data for internal review and to follow up on investigations of suspicious orders being placed and delivered across the US.

So what constitutes a suspicious order?

Jack Teitelman, retired DEA supervisory agent and current chief executive officer of DEA compliance experts Titan Group, told NEWStat that “One of the biggest red flags is a change in controlled substance ordering patterns.”

Teitelman give this example: “A regional DEA diversion inspector might start by looking at ARCOS reports from their area (say, Denver), and they’ll ask themselves, ’Who are the largest purchasers of fentanyl in this city? Let’s see, number one is Denver Regional Hospital, makes sense; number two is Denver Memorial Hospital, sounds about right; and number three is—Whaaat? What’s Neighborhood Veterinary Hospital doing on this list? And how come they’re ordering 200 vials of fentanyl a month?’”

That would be a pretty good question.

But Teitelman says that inspector might be seeing a problem that doesn’t exist because veterinary hospitals are still new territory for most DEA diversion investigators: “They understand a human hospital. They understand a pharmacy. But they walk into a veterinary hospital, and they’re on a different planet.”

Teitelman says that’s because the main focus of past DEA diversion investigators was on “the big guys”: human hospitals, pain clinics, pharmaceutical manufacturers and distributers. “They might spend 5% of their time looking at veterinary hospitals.”

That means they often aren’t familiar with veterinary drug ordering issues, such as those posed by the  ongoing fentanyl shortage. “Some hospitals put in orders  with multiple suppliers, hoping that one will come through,” Teitelman explains. “Then one day, for some reason, they get all their orders filled at once. And that raises a red flag at the DEA—[In their eyes] that hospital just ordered ten times as much fentanyl as they’ve ever ordered before.”

Boom—instant audit.

“We knew [the shortage-driven change in ordering patterns] was going to raise red flags and we knew some of our clients were going to get phone calls,” Teitelman adds. “And of course, they did,”

In short, Teitelman says, be vigilant: “The microscope has been turned on, where it hasn’t been turned on before. [The DEA is] paying attention to ordering patterns, which they didn’t really care about before.” If yours trigger an audit, “that brings them inside your house.”

And once they’re in, it can be tough getting them out.

Photo Credit: © iStock/Evgeny Gromov