2024/2025
If a person registered to distribute CS discovers reportable theft or loss, who
must be notified in what time frame - ANSWER--DEA in writing within one
business day upon discovery and keep a copy of that notice for its records
-State Police
-MA BOP with the board special form within 7 days
If a person registered to dispense CS discovers theft or loss, with who must a
DEA 106 form be filed - ANSWER--DEA in writing within one business day upon
discovery and keep a copy of that notice for its records
-State Police
-Police department in the city or town were the theft occurred
-MA BOP with the board special form within 7 days
What is included on a DEA 106 form - ANSWER-1. Name and address of the firm
(pharmacy),
2. DEA registration number,
3. Date of theft or loss (or when discovered if not known),
4. Name and telephone number of local police department (if notified),
5. Type of theft (e.g., night break-in, armed robbery),
6. List of identifying marks, symbols, or price codes (if any) used by the
pharmacy on the labels of the containers, and
,7. A listing of controlled substances missing, including the strength, dosage
form, and size of container (in milliliters if liquid form) or corresponding National
Drug Code numbers.
How often must a pharmacist dispensing opioid antagonist (naloxone) report the
quantity of dispensing they have done - ANSWER-annually
The pharmacy or pharmacy department shall report a theft or loss of significant
amount of controlled substance by submitting the board special form - ANSWER-
within 7 days of such theft
When must losses related to employee pilferage or diversion be reported to the
board - ANSWER-always (significant or otherwise)
When must losses related to C II - VI substances be reported - ANSWER-
Significant loss only
When a loss is due to a confirmed dispensing error, does this have to be
reported? - ANSWER-No
Who is responsible for reporting theft or loss to the DEA via DEA 106 form for in-
transit losses? - ANSWER-Whoever has custody of the product (aka supplier,
would be the purchaser if they have signed for or taken custody)
Who is responsible to report in-transit loss when a retail pharmacy contracts with
private, common, or contract carriers to retrieve filled prescriptions from a central
fill pharmacy - ANSWER-the retail pharmacy is responsible for reporting in-transit
losses upon discovery using a DEA Form 106.
Does the witnessed breakage or spillage of a controlled substance constitute a
loss? - ANSWER-does not constitute a loss of controlled substances because the
registrant can account for the controlled substances, the DEA does not have to
be notified
How must non-recoverable CII product breakage or spillage be handled? -
ANSWER-Recorded on a DEA Form 41 and signed by two individuals who can
testify that a breakage or spillage occurred.
For significant breakage or spillage, who is responsible for filing DEA form 41 -
ANSWER-The reverse distributor
, What is the procedure for sending CII substances to a reverse distributor -
ANSWER-the reverse distributor must issue an official order form (DEA Form 222)
or the electronic equivalent to the pharmacy, they are responsible for filing the
DEA 41 form upon destruction
What is the procedure for sending CIII-V substances to a reverse distributor -
ANSWER-the pharmacy must maintain a record of distribution that lists the drug
name, dosage form, drug strength, quantity, and date transferred.
How can a LTCF dispose of CS for an ultimate user who resides, or has resided,
at such LTCF? - ANSWER-transfer those controlled substances into an
authorized collection receptacle located at that LTCF within 3 days of drug
discontinuation
Who may install, manage, and maintain collection receptacles at LTCFs -
ANSWER-authorized retail pharmacies and authorized hospitals/clinics with an
on-site pharmacy
How much personel (pharm tech, certified pharm tech, intern) can a pharmacist
directly supervise? - ANSWER-A single pharmacist can supervise up to 2 goons
and 2 champs at once
When can a pharmacist supervise up to 4 interns - ANSWER-If they are not all in
the pharmacy and directly impacting dispensing (OK if they are immunizing)
When does pharm tech registration expire - ANSWER-every 2 years on their
birthday
How often must an RPh's perpetual inventory of C II be reconciled - ANSWER-
every 10 days
What is involved in an RPh's perpetual CII inventory - ANSWER-CIIs which RPh
has received, dispensed or disposed of in accordance with law
Under what circumstances can a CIII - V prescription be transferred - ANSWER--
Pharmacist and interns only may transfer
-Can only transfer these Rx once, must be filled once first before transferring
What must be recorded when a CIII-V prescription is transferred - ANSWER--
Transferring RPh write VOID on face of invalidated Rx