Requirement applies to requests from one registrant to another
All U.S. Drug Enforcement Administration (DEA) registrants, including veterinarians, are now required to design and operate a system to identify suspicious orders they receive from another registrant – such as another veterinarian – and to report those suspicious orders to the DEA.
In this context, an order includes a request from another veterinarian to transfer a controlled substance from one practice/location to another – for example, the transfer of ketamine.
The good news is that the impact on veterinarians who are DEA registrants and veterinary practices should be negligible, and compliance should be relatively straightforward. The AVMA has developed a template that can be used as a resource when developing a system.
Why is this reporting necessary?
The reporting requirements were established in a law passed last year by Congress: the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act, also known as the SUPPORT Act.
The DEA recently launched the Suspicious Orders Report System (SORS), a centralized database required by the law, where DEA registrants who distribute controlled substances must report suspicious orders from other registrants.
The reporting requirement applies anytime a registrant, including a veterinarian, is asked to provide a controlled substance to another registrant under circumstances identified as suspicious. Suspicious orders include requests from another DEA registrant for controlled substances of unusual size, those deviating substantially from a normal pattern, and orders of unusual frequency, as well as orders that seem suspicious to the receiving registrant for any other reason.
How to report suspicious requests
The reporting requirement and SORS online database are solely for reporting requests for transfers of a controlled substance from one DEA registrant to another that seem suspicious. If a request to transfer a controlled substance to another registrant does not raise suspicion, there is no need to report it.
The system also is not for reporting any activity related to the administration, prescribing, or dispensing of controlled substances in the ordinary course of veterinary practice. Veterinarians should not use it to report suspicious or drug-seeking behavior by clients.
If a veterinarian believes a request to transfer a controlled substance to another practitioner is suspicious, the veterinarian should take the following actions:
- Do not supply the controlled substance.
- Report the order to the online database (SORS).
- Document the circumstances of the request that precipitated the report to SORS, and retain that information with your system records.
The DEA advises that the system to identify suspicious orders should be maintained in writing and could be requested during an inspection.
A veterinarian only needs to register for the database when they need to file a report of a suspicious order.
AVMA template helps you meet the requirements
The AVMA has developed a template that can be used by AVMA members who are veterinary DEA registrants when developing a system for reporting suspicious orders. It’s intended only as a resource. The template includes a fact sheet outlining the reporting requirements.
The DEA also has developed an FAQ page to help registrants understand the reporting system and its requirements:
The DEA will develop rules that will be published in the Federal Register, and AVMA will review the rules and respond as appropriate. Because this is a new program, it’s very likely DEA guidance will change over time. We’ll keep AVMA members informed as this happens.