Controlled substances used in your veterinary practice are serious business. They are highly regulated drugs that need to be securely stored and accounted for at all times. That’s why a call from the Drug Enforcement Administration is to be taken very seriously.
When some AVMA members in California were recently contacted by the agency to confirm their place of business, they reached out to us to help clarify concerns that perhaps the DEA might be changing its enforcement of the Controlled Substances Act. We did some digging and were told by our DEA contacts in Washington, D.C., that this was “just a regional office confirming that the home address is, in fact, the principal place of business for this registrant.”
Home addresses are frowned upon by the DEA as storage places for controlled substances, largely because of concerns about practitioners (not just veterinarians) having controlled substances delivered to their home address for personal use or abuse, and not a use that’s in accordance with the Controlled Substances Act.
Although the situation appears to be limited to California at this time, the DEA’s concerns are a symptom of an underlying, national-level problem because the Controlled Substances Act wasn’t written with veterinarians and their unique circumstances in mind, and therefore doesn’t address veterinarians’ frequent need to transport controlled substances on house calls or farm calls. Although we’ve been assured by the national DEA office that the agency understands veterinarians’ needs and acknowledges the shortcomings of the Controlled Substances Act regarding our profession, we’re concerned that any change in this position could bring many veterinary practices to a standstill and prevent veterinarians from providing quality veterinary healthcare to their patients.
We recently sent a letter to the DEA, requesting that, until the Controlled Substances Act is amended, the agency exercise enforcement discretion when investigating ambulatory veterinary practitioners who are licensed by the state to practice veterinary medicine and hold a valid DEA registration for their principal place of business. Our efforts, however, will not stop there. We are still actively involved in discussions with the DEA, and we’re talking with congressional offices about the issue. We promise our members that we are aggressively advocating for the profession on this issue, and we will keep you informed through the AVMA blog and our NOAH discussion boards as the process continues.