DEA Registration - Mpje
- Which option best states whether a POA for DEA Form 222 can be limited to specific schedules or tasks?
- Yes; the registrant may limit POA scope in the written authorization. Registrants can customize POA limitations in the document to control delegation scope, such as restricting to certain schedules or activities.
- Which option best states whether a DEA registration is location-specific for a pharmacy?
- Yes; a separate DEA registration is generally required for each location. DEA registrations are tied to specific business locations to enable precise oversight and prevent cross-site diversion of controlled substances.
- What must be done with a revoked POA for DEA Form 222 to remain compliant?
- Maintain the revocation document with records; POA is no longer valid. Retaining the revocation ensures documentation of invalidation, preventing unauthorized use of the former POA.
- What is the required documentation if a registrant wants to revoke an individual's POA to sign DEA Form 222?
- A written revocation signed by the registrant; keep it with POA records. A signed revocation document provides formal notice of termination, which must be retained to document compliance.
- Identify the event that automatically ends a POA to sign DEA Form 222 for a specific individual.
- Termination by registrant, or the individual leaves the registrant's employment. Automatic termination upon employment end or registrant action safeguards against misuse by individuals no longer affiliated with the entity.
- Identify who may grant power of attorney to execute DEA Form 222 for a registrant entity.
- The registrant (person who signed the DEA registration application). Authority to delegate signing privileges for Form 222 resides solely with the individual who applied for and holds the DEA registration.
- Identify the correct response: a POA grantee transfers to another store under the same chain.
- POA does not transfer; new location/registrant must execute a new POA. POA is registration-specific and does not carry over to new locations, requiring fresh authorization to align with the new site's DEA registration.
- Identify whether CSOS ordering requires the same POA concept as paper DEA Form 222 ordering.
- Yes; only authorized individuals may place CSOS orders for the registrant. CSOS electronic ordering parallels Form 222 by restricting placement to individuals authorized via a similar POA framework for security.
- Identify the compliance issue: a technician signs DEA Form 222, but no POA is on file.
- Invalid execution of DEA Form 222; must be signed by registrant or POA grantee. Signatures on Form 222 by unauthorized individuals, such as technicians without POA, violate DEA rules designed to prevent diversion.
- Which option best states whether a POA is required to sign Schedule III–V purchase invoices?
- No; POA rules apply to DEA Form 222/CSOS, not III–V invoices. POA requirements are specific to Schedule II orders via Form 222 or CSOS, while Schedules III-V use standard invoices without such restrictions.
- What is the DEA form used to grant power of attorney to sign DEA Form 222 for a registrant?
- DEA Power of Attorney (POA) document; no DEA-issued form is required. The DEA mandates a written document for granting POA, without requiring a specific agency-issued form to authorize signing of Form 222.
- Which option is required for a valid POA to sign DEA Form 222: notarization or witnesses?
- Two witnesses are required; notarization is not required by DEA. DEA regulations require two witnesses to attest to the registrant's signature on the POA, but do not mandate notarization for validity.
- What is the minimum signature requirement on a DEA Form 222 executed under power of attorney?
- Signed by the POA grantee (or registrant) exactly as authorized. Signatures on Form 222 must conform precisely to the POA authorization to ensure accountability and validity of the order.
- Identify the correct action if the registrant changes (new owner/new registrant) at the same location.
- Execute new POAs; prior POAs are not valid for the new registrant. A change in registrant invalidates existing POAs, necessitating new documents to reflect the current authority structure.
- What is the registrant's DEA registration number used for on controlled substance orders and records?
- It identifies the specific registrant authorized to handle controlled substances. The unique DEA registration number serves as an identifier to confirm the entity's authorization for controlled substance activities in orders and records.
- What is the DEA requirement for a witness on a POA to sign DEA Form 222?
- Witnesses must be present when the registrant signs the POA document. Witnesses must observe the registrant's signing to verify the act and prevent disputes over the POA's legitimacy.
- Identify whether a pharmacist-in-charge automatically has POA to sign DEA Form 222 at a pharmacy.
- No; POA must be explicitly granted in writing by the registrant. POA for Form 222 must be deliberately granted in writing, as the pharmacist-in-charge role does not confer automatic authority.
- What is the correct action if a pharmacy receives Schedule II drugs but the receiving staff lacks POA?
- POA is not required to receive; POA is required to execute DEA Form 222/CSOS. POA is necessary only for ordering execution, not for receiving Schedule II substances, allowing staff to accept deliveries without it.
- Identify the required signers on the POA document granting authority to sign DEA Form 222.
- Registrant signature plus two witness signatures. The POA document requires the registrant's signature witnessed by two individuals to confirm authenticity and voluntary granting of authority.
- What recordkeeping rule applies to the original POA document for executing DEA Form 222?
- Maintain the original POA at the registered location with DEA records. Storing the original POA on-site with other DEA records allows for easy verification during compliance inspections.
- What is required before a POA grantee can begin signing DEA Form 222 for a registrant?
- A written POA signed by the registrant and witnessed by two individuals. A formal written POA, signed by the registrant and attested by two witnesses, establishes legal delegation before signing can commence.
- Identify who may sign a DEA Form 222 if no POA has been executed for any employee.
- Only the registrant (the individual who signed the DEA registration application). Without POA delegation, signing authority for Form 222 is limited to the registrant to maintain direct accountability.
- Which DEA form is used to order Schedule II controlled substances from a supplier?
- DEA Form 222 (paper) or CSOS electronic order. Schedule II controlled substances require secure ordering methods to track and prevent diversion, utilizing either paper Form 222 or electronic CSOS systems.
- Which option best states whether a corporate officer may sign DEA Form 222 for a pharmacy without POA?
- Only if that officer is the registrant; otherwise a written POA is required. Corporate officers lack inherent authority to sign Form 222 unless they are the registrant or have received explicit POA.
- Identify who may receive power of attorney to sign DEA Form 222 for a registrant.
- Any individual the registrant authorizes in writing (POA grantee). The registrant has discretion to delegate signing authority via written POA to any trusted person to facilitate controlled substance ordering.