In the world of veterinary medicine, transitions happen. Doctors retire, move to different facilities, or shift roles. But when that individual holds the DEA registration used to order and manage controlled substances, the changeover is not business as usual – and certainly not as simple as handing over a clipboard and saying “good luck.”
Let’s break down why this moment of change requires more than a handshake, and what’s at stake if your practice isn’t buttoned up.
The Controlled Substance Inventory Doesn’t Just “Transfer”
Controlled substances registered under a specific DEA number are considered the property of that registrant. That means if Dr. Smith is the outgoing registrant, those drugs still legally belong to Dr. Smith until they are transferred according to DEA (and state) regulations.
This is where many practices get it wrong. Without compliant documentation, tailored to the schedule of the medications involved – the handoff becomes a legal gray area. The DEA will expect to see a clear, complete paper trail showing that every milligram was accounted for, legally transferred, and appropriately logged. And they’ll ask both the outgoing and incoming registrants to explain any gaps.
Why Documentation Matters More Than You Think
You won’t find a checklist taped to the wall from the DEA telling you exactly what to do in these scenarios. That doesn’t mean you’re off the hook.
The truth is, the DEA will ask to see transfer documentation if they visit your facility post-transition. And if it’s missing, incomplete, or not readily retrievable? You’re looking at potential violations, increased scrutiny, and possible fines. Even more concerning – both registrants could be held accountable if there’s no clear record of the transfer, inventory counts, or handoff procedures.
It’s not about being overly cautious, it’s about being defensible.
Don’t Forget to Update Distributors and Systems
Once the DEA transfer is complete, there’s still work to do:
- Vendors and Distributors: Make sure the facility’s suppliers are updated with the new DEA registrant’s information immediately. Continuing to place orders under the old DEA number – even accidentally – can raise serious red flags.
- Practice Management Systems: Many systems autofill the DEA number for prescriptions and logs. If the change isn’t made in all the right places, it could result in inaccurate records, misattributed prescribing, or noncompliance with PDMP reporting in certain states.
- Inventory Systems: Any software or manual logs tracking drug inventory must be updated to reflect the new registrant. This ensures accuracy in reporting, documentation, and reconciliation.
Bottom Line: Protect the Facility and Everyone Involved
Whether you’re a corporate compliance officer or the onsite DEA registrant, the changeover process should be treated as a formal, compliant transition, not an informal pass-off. There’s too much at stake to assume good intentions are enough.
By taking time to document properly, involve the right parties, and update systems and vendors, you protect not only the incoming and outgoing doctors but your entire facility from regulatory headaches.
Because when the DEA comes knocking, they’re not interested in how nice the transition was, they want to know it was legal.