Weight Debate: Should You Implement a Weight Protocol for Controlled Substances?

Most veterinary practices still track their controlled substances (and fill out their records) by estimating the amount of the substance used, either by eyeballing the amount from a bottle or vial or drawing contents into syringes to calculate measured amounts. However, in the human healthcare field, pharmacies and labs often use weight as their standard tracking system to maintain the most accurate and consistent records. Is the same practice worth considering for the veterinary community?

The most important safety measure you have against DEA action is your controlled substance records.

by Jess Townsend

One of the most confusing and stressful aspects of veterinary hospital management is navigating controlled substance recordkeeping and ensuring compliance with the Drug Enforcement Administration (DEA). This is especially true considering the opioid epidemic and the resulting increase in scrutiny that the DEA has given to the substances being abused. Veterinary practices across the country have seen increased DEA audits and inspections happening as a result of the agency’s commitment to identifying and charging drug diversion. In light of the DEA’s renewed attention, veterinary staff and practice managers need to take extra care with their practice’s policies around controlled substances.

The most important safety measure you have against DEA action is your controlled substance records. Jack Teitelman, retired DEA supervisory agent and CEO of TITAN Group, points out that “if the DEA knocks on your door and you can tell them with the utmost confidence the whereabouts of every drug that enters your doors, goes into your safe, is administered to an animal, or is sent to the reverse distributor, you will never have a problem.”

For veterinary staff, that means having a complete and accurate record of the controlled substances in your practice. According to the Code of Federal Regulations (CFR), “Each registrant who maintains an inventory of controlled substances must maintain a complete and accurate record of the controlled substances on hand and the date that the inventory was conducted.”

But most veterinary practices still track their controlled substances (and fill out their records) by estimating the amount of the substance used, either by eyeballing the amount from a bottle or vial or drawing contents into syringes to calculate measured amounts. However, in the human healthcare field, pharmacies and labs often use weight as their standard tracking system to maintain the most accurate and consistent records. Is the same practice worth considering for the veterinary community?

Anthony Merkle, CVT, member experience regional manager of AAHA, says it is. “The DEA does not distinguish between a human medical facility or a veterinary medical facility, so the veterinary community should consider taking the same level of safety and precaution that our counterparts do in human medicine.”

Weighing Results in the Most Accurate Records

Teitelman asserts that “weighing your controlled substances is the most accurate method for creating and maintaining records, which is the DEA’s core compliance requirement.” Weight is a direct measure of the substance itself, whereas the volume of a vial or bottle will include variable amounts of empty space. For example, “In the kitchen, one teaspoon of granular table salt can be twice as much salt as a teaspoon of flake salt,” said Teitelman.

Furthermore, tracking drug weights will account for the natural variances in the amounts between bottles and vials. “Most manufacturers underfill or overfill every bottle and vial of liquid sold—maybe by tiny amounts, but it still happens,” says Teitelman. This means that, even with the most rigorous logging, you can still have overages or shortages in your logbooks because a bottle that was labeled as 10mL actually contains 10.75mL.

“When I was in practice, overfill was often an issue when reconciling our controlled substance logbooks,” said Merkle. But weighing the drug when it is received and put into inventory will catch these inaccuracies and will save you from doing convoluted math—or struggling to explain the discrepancy during a DEA audit.

An Early Warning System for Diversion

With a more accurate tracking method also comes a better method for catching potential diversion. In his time in veterinary practices, Teitelman has seen that “tracking weight becomes an excellent early warning system for misplaced drugs.” In addition to adding a weighing protocol, he recommends daily logging and reconciliation, if you can manage it. A frequent auditing process allows you to catch a discrepancy almost as soon as it occurs. Any discrepancies at the end of the day or the end of a shift must be investigated, and any abnormalities need to be elevated to the witnessed DVM for disposition. Teitelman cautioned that this applies only to those discrepancies that cannot be reconciled by normal hub waste (defined as 0.05mL per draw). When diversion is suspected, the hospital can then take action to correct the problem—whether due to incorrect recordkeeping, an unusual event, or even abuse—as soon as possible.

Implementing a Weight System in Your Practice

For anyone balking at the thought of adding yet another step to their controlled substance recordkeeping, Teitelman asserts that weighing can actually “save you and your team time in the long run, since you won’t spend time accounting for overages or shortages in your records.”

To get started, your practice should first invest in a quality gram scale that will weigh to 0.01g, which typically costs around $50 to $100. Then establish a new protocol that includes weight tracking for authorized staff.

Teitelman recommended that a drug’s weight should be taken when the substance is received into your unopened stock, and when transferring a bottle from unopened to opened stock when the seal is removed. At a minimum, the substance should also be weighed each time the drug is extracted for dosing. Lastly, a final weight should be taken and recorded at the end of each bottle, or when the drug has expired and is being sent for disposal.

Follow up any new weight protocol with thorough training for staff who will be using it. Merkle stressed the importance of staff training in order to be successful. “When handling controlled substances, a DVM is putting their life and license into the hands of the authorized personnel on the team, so the training should be taken extremely seriously on both sides of that relationship. There should be a huge level of accountability and trust between both parties and an emphasis on training and mutual ownership of the new process.”

Committing to a small extra step and some additional training, however, could have a big overall impact on the accuracy of a practice’s records, not to mention the peace of mind that comes with knowing your practice is protected from any unwanted DEA action. Once implemented, a weighing protocol will ensure that your practice stays safe and DEA compliant.

Jess Townsend is a writer, marketer, and dog lover living in Denver, Colorado.

 

Photo credits: ©iStock.com/stphillips, ©iStock.com/efa ozel

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