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DEA Presentation. Special thanks to Dr. Larry Miller from San Antonio for a presentation on “Lessons Learned”. Copy 3. DEA Personnel. Sharnett Latimore, Houston Area David White, Fort Worth Area Samuel Kemp, San Antonio Area. DEA Words to Remember. Stored Handled Dispensed Administered

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Presentation Transcript
dea presentation
DEA Presentation
  • Special thanks to Dr. Larry Miller from San Antonio for a presentation on “Lessons Learned”
dea personnel
DEA Personnel
  • Sharnett Latimore, Houston Area
  • David White, Fort Worth Area
  • Samuel Kemp, San Antonio Area
dea words to remember
DEA Words to Remember
  • Stored
  • Handled
  • Dispensed
  • Administered
  • Distributed
dea highlights
DEA Highlights
  • EMS is not specifically regulated in current Federal law or regulation
  • DEA does not “license” EMS units (i.e. mobile assets)
  • Texas is covered by 4 DEA field offices and each can have different “interpretations” of DEA regulations
  • Technical “guidance” can be obtained through local field office that will forward it to Washington D.C. These results will not be publicly disseminated by the DEA
scenario 1
Scenario #1
  • An EMS agency stores all controlled substances in a secure spot at their headquarters. From here, medications are placed on the ambulances which then stay at outlying stations. There is no storage of medications at the outlying stations except what has been issued to the ambulance stationed there. Re-supply comes from the headquarters.
  • DEA allows this with a SINGLE DEA license for the headquarters building.
scenario 2
Scenario #2
  • An EMS Agency stores main inventory of controlled substances at its headquarters building. Each EMS Station also has a secure location where “inventory” is kept for that station and the ambulances resupply from “inventory” at their respective stations and the stations are re-supplied from the headquarters storage.
  • DEA allows this if the headquarters has a “Distributor” License and each station has an individual DEA license.
  • Distributor license is much more intensive than normal DEA license EMS agencies are getting now (including regular audits and inspections by DEA)
  • Each station would need to utilize 222 forms to request Schedule II medications from headquarters
scenario 3
Scenario #3
  • Single station agency, not staffed 24/7. Controlled med inventory locked up and meds are issued to the ambulance(s) from the central inventory. Meds are secured on the ambulance and records kept on inventory.
  • DEA had no issues with this other than making sure agency has their DEA and DPS license
scenario 4
Scenario #4
  • An EMS agency is requested to the local ED to transfer a patient to a higher level of care. The sending physician gives report to the crew and issues them controlled medications “in case” the patient takes a turn for the worse. These are meds not normally carried by the EMS Provider. If the meds are not used, the meds are returned to the sending hospital.
  • DEA officials had “visible” reaction to this scenario. Many caveats were discussed and DEA suggested this Scenario be sent in for technical guidance from Washington D.C.
scenario 5
Scenario #5
  • An EMS agency follows Scenario #1, but at their outlying station, the ambulance is kept outdoors. It is locked at all times, but is not in a building.
  • DEA had some concern about this and stated it would be imparative to make sure that a high level of security was in place at all times. DEA gave no firm commitment to the appropriateness of this.
scenario 6
Scenario #6
  • A rural EMS agency has controlled meds on their ambulance per Scenario #1. For operational reasons, the ambulance at night goes home with the crew member(s) to shorten response times at night. The narcotics are kept on the ambulance like Scenario #5 but the location of the ambulance is the crew member’s residence.
  • Another “visible” reaction from DEA officials. They were adament that personnel could not take controlled meds home with them on their person. They were not willing to commit to the appropriateness of doing this in an EMS vehicle (ambulance or staff vehicle) and suggested this scenario also be sent in for technical guidance.
Scenario #?
  • If your agency has a different situation, you can write up your specific scenario and submit to the DEA local office for technical guidance.
  • Results ARE NOT shared by DEA like OIG does for Medicare questions, but your agency could share those as you see fit.
  • If you would like to suggest other scenarios for inclusion in the EMS Committee’s letter, email them to [email protected] or [email protected]
  • Goal is to have letter to DEA on September 1.