DEA inspection.

Buprenorphine Post
Posts: 35

Postby compchat57 » Tue Feb 18, 2014 11:48 am

I'm new to this and have no computerized chart system. My concern with DEA is that they will wish to randomly audit ALL charts even those that are not being treated with BUP. We've separated the charts by color and I'm wondering if that is sufficient. For instance Blue Charts are for BUP patients only. Would the DEA be entitled to look at all my charts or only the Blue Charts (BUP patients)? Of course as a general internist the vast number of charts are non bup patients.

Posts: 1

Postby algosdoc » Tue Feb 18, 2014 11:48 am

An X number from the DATA 2000 registration is required only for addiction treatment with buprenorphine products. The use of suboxone or buprenex or zubsolv or bunavail or generic SL buprenorphine for pain does not require an "X" number, but in such cases would suggest performing a DSM4 or 5 Addiction Screen to****ure they really are not addicts.

Michael L. Whitworth

Posts: 16

Postby catschollmd » Tue Feb 18, 2014 11:48 am

Had first DEA inspection recently after 2 1/2 yrs. My understanding is IF you dispense (stock to do induction) it must be every 2-3 yrs but if only writing within every 5 years. 2 very nice gentlemen came out, Very pleasant. we use Stratus EHR, is dedicated to addiction medicine only. But we still keep that DEA log sheet that Suboxone web site used to give out and a weekly up to date active list. They like that because they didn't have to handle any charting or computer.ONLY comment I got was did I write pt address in address line on Rxs. (not usually unless out of state) they said no one does but it is the DEA law. and they are there to help and answer questions. was quite pleasant actually. and informative.

a problem no one seems to be able to help with..have had multiple calls into DEA and into Drug board at albany, NY and Harrrisburg, PA (my 2 states) ALL say the same thing..IF sub lingual it is for addiction ONLY and if patch or injectable is for pain "and ner the plains shall meet" SO those chronic pain patients who have become addicted (have WD) (16-20% chronic pain pts will become addicted..but they are not not meet DSM4 criteria..5 is changing..what do you do.. I do give them Butrans if insurance covers it but buprenorphine is not a very strong pain med. and those on SL breakup doses as pain effect for bup is short (4hrs)

so very surprised about an above comment when someone said he Rx'd SL bup without x number for pain and didnt added to his 100 list. anyone else ever do that or been told they could by DEA. Definitely not what feds or states have told me..would love to hear from you about this
you do NOT need X for Butrans but do for ALL forms of SL bup

Jeremy K
Posts: 109

Postby Jeremy K » Tue Feb 18, 2014 11:48 am

Wow third one! I've been Rx'ing Suboxone for ~ 3 years, so far no sign of the DEA. I remember reading somewhere the goal was they would inspect everyone Rx'ing Sub for OST; anyone know how close to that goal they are? Is it even a reasonable goal anymore, considering # of docs involved v.v. available agents? Just curious...

Posts: 571

Postby kcairns » Tue Feb 18, 2014 11:48 am

3rd one yesterday, have gone from first being prosecutorial, to second being reasonable, to 3rd cordial and i like to believe w feeling we are on same side in commitment to help overcome America's opioid public health crisis

Posts: 17

Postby klsloan » Tue Feb 18, 2014 11:48 am

I had a DEA inspection (my first) about a week and a half ago. My medical record is entirely electronic and prescriptions are printed by the software. The inspectors wanted my current list and a listing of buprenorphine prescriptions I have written over the last 2-3 months. Prior to the visit I configured an electronic report to provide that information. When they were in my office I printed the report (which included information including a patient seen that morning) and they were entirely happy with it. They made no requests for additional "hard copy" records or photocopies of prescriptions.

Posts: 111

Postby fishdoc » Tue Feb 18, 2014 11:48 am

Software generated are sufficient, and perhaps preferred as it would be more difficult to alter and the software itself contains an exact copy of what you wrote.

I have found, however, that PracticeFusion has made it impossible to correct a prescription once it is saved. For example, if you write 20 films and realize the patient will need 18, you can no longer change the rx, but instead need to write that it was and error and write a new one. I do not know if Allscripts makes changes this difficult.

Posts: 180

Postby entjwb » Tue Feb 18, 2014 11:48 am

Need to check with State Board. Each state might be different. We have asked that same question because the computer keeps a record of the Rx which is what is required.

Posts: 198

Postby NoDrugs4u » Tue Feb 18, 2014 11:48 am

What if you are using software generated Rx's, such as with Practice Fusion or Allscripts? Is the electronic record sufficient or do you need to print two of everything?

Signed - NoDrugs4u
I am new to this, please be gentle with me...

Posts: 1404

Postby drpasser » Tue Feb 18, 2014 11:48 am

You know, I use prescriptions that have a carbon copy for each one. I just staple to copies in the charts, no need for Xeroxing.

Anyway, I didn't know if you knew about the Rxs with the copies already attached.


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