Most veterinary practices are fast-paced workplaces with frequent emergency situations that require split-second decisionmaking. In other words, environments in which unexpected or unusual “near miss” events with your controlled substances are likely. In order to meet the DEA’s core compliance requirement of creating and maintaining the most accurate records possible, a specific protocol for logging these events is essential.

What is a near miss incident?

A near miss incident is an unplanned event that has the potential to cause, but does not actually result in, an interruption to your practice operations. Think of them as weird or unusual events that occur within a normal practice, such as a dropped bottle, or controlled substances that weren’t properly logged in the rush of a medical emergency—all of which are likely to happen in a busy and hectic hospital environment. Creating a written record of near miss incidents will allow you to track these events or any interactions with your controlled substances that do not have an explicit logical explanation.

Why record these events?

The DEA expects your controlled substance logs to tell an accurate story about your drugs. Properly logging every irregularity gives you a level of security by having better control over your controlled substances and can protect you and your practice from fines and allegations of diversion by the DEA. And properly logging every anomaly can also help you and your staff to recognize patterns in your controlled substance management. This enables you to step in before a few unusual events become a larger problem, such as diversion or a staff member mishandling drugs in the practice.

How do I implement a near miss incident protocol?

Create a space in your existing log system for recording a near miss incident, or integrate a log system that has the feature built in. Record the date, time, and staff member reporting the incident, along with a description of the issue or event that occurred and what was done in response. Also include the date the DEA registrant was notified of the issue and explain how the issue was resolved. Finally, the staff member who resolved the incident will initial and date the log to finish the report.

Teach your staff exactly what near miss events are and how to log them properly. Training staff members who will be involved in using each log is imperative for a successful controlled substance protocol.

It is also crucial to get in the habit of logging irregular events as soon as they happen or are noticed in your practice. Time is truly of the essence and will ensure that the event is logged accurately. It is much easier to tackle the task when the event is fresh in your mind rather than revisiting it days later, or, even worse, trying to think back on events when auditing records in the future.

Implementing a near miss incident protocol can help ensure your practice and staff stay safe.

Ensure your practice is meeting the DEA’s stringent recordkeeping requirements with the newly updated edition of the AAHA Controlled Substance Logs.

About the author

Jack Teitelman is a contributor to the AAHA Controlled Substance Logs and a retired DEA supervisory special agent who spent 26 years gaining extensive experience in all facets of complex criminal drug-conspiracy investigations. As founder and CEO of TITAN Group, Teitelman directs a team of leading DEA compliance and state regulatory compliance experts and investigators to ensure that veterinary clients receive the highest quality services and support.

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