"The DEA never shuts down,” said Jack Teitelman.

Not even during a pandemic.

Teitelman, a retired Drug Enforcement Administration (DEA) supervisory special agent and founder and CEO of DEA compliance experts TITAN Group, told NEWStat that, if anything, “They actually got more focused.”

Which means that, unlike many state and federal agencies that temporarily closed offices, limited operating hours, and went online to conduct business during the pandemic, the DEA never stopped performing onsite inspections.

Teitelman said he’s seen DEA agents show up at veterinary hospitals during the pandemic for three main reasons, to investigate:

• Anonymous complaints from disgruntled employees
• Suspected drug diversion by hospital staff
• Unexplained losses or thefts that required a hospital to submit a DEA-106 form to the agency

Poor recordkeeping is a major factor.

Practice staff know how busy they’ve been during the pandemic, and Teitelman said he often sees that chaos reflected in recordkeeping. He ticks off some of the most common problems he’s seen: failure to submit timely prescription drug monitoring program reports, failure to maintain continuing education, improperly performed inventories, incomplete records of receipt and dispensing, and a lapse in employee screening.

“Always keep in mind that every recordkeeping violation could potentially turn into a monetary penalty,” he warned. “That’s why we preach continuous staff training on proper recordkeeping.”  

The good news is that the DEA made one major change to their protocols early on: At the end of March 2020, they eased requirements for chain of custody records for ordering schedule I or II drugs.

Registrants using paper-triplicate Form 222s normally must complete the form and mail copies one and two to the supplier. (Suppliers then complete their portion of the forms, retain one copy, and send the last copy to their local DEA office.)

In light of the pandemic, the DEA’s exception allowed hospitals to email or fax the forms to the supplier instead. Once the pandemic’s over, you’ll still have to mail them to the suppliers.

But monitoring controlled substances has been of particular concern during the pandemic due to the increased risk of substance abuse as a means of coping with stress.

Substance abuse is up overall during the pandemic as people have struggled to cope, and so is the number of prescriptions for controlled substances written by physicians—prescriptions for antianxiety drugs alone jumped 34% in the first weeks of the pandemic.

Teitelman said veterinarians are also writing more prescriptions for controlled substances, largely because housebound owners are more attuned to—and seeking treatment for—signs of distress in their pets.

Teitelman said he’s seen a noticeable jump in diversion but advises practices to install cameras overlooking drug safes and treatment areas to keep a closer eye on controlled drugs.

Staying on top of controlled substance monitoring is the best way to avoid problems with the DEA, Teitelman said, and consistency is the key: “Lack of oversight can cause serious issues with the DEA. [So] have a plan and stick with it.” Even during a pandemic.

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