It's going to be a short post today but an important one, so keep reading!
About a week or two ago one of the other pharmacists at my pharmacy came to me asking what to do with the 222 form from McKesson, now that there aren't three copies. She handed me the form, a full sheet of paper (and just one sheet of paper), along with their notice about it, to which my response was ...
"What is this?"
Meet the new 222s.
There was probably a previous notice from McKesson somewhere that I missed, but the DEA has finally done away with the triplicate forms and might at least be in the 20th century now (I'm not sure I would put them in the 21st century just yet). All I can say is that it's about time.
I've never personally seen what they do with all those green copies they've been hoarding all these years, but I've always pictured their warehouse of 222s looking something like this:
There's nooooo way they've been filing everything neatly, sorted by DEA number or location, so they can quickly pull the data off of it to look for purchasing patterns.
In other words, in paper format, and with the volume of forms they receive, it's going to be extremely difficult/impossible for them to glean anything useful from them, and so they have really just been a waste of time for the pharmacy and the DEA.
RIP Green 222.
While I have no idea if they'll get any useful information from the new forms, they are at least less of a hassle.
Now, onto the new form! Here's what you need to know about them:
1. The Official Notice
Here's the link to the notice so you can read it straight from the horse's mouth, if you prefer. There are a couple other minor things on there as well, but we'll focus today on the 222s.
Here's the link to the final rule, after being amended. This is the one to bookmark until you're fully used to the new process.
2. You can keep using the old forms up
I would recommend, if you do use 222s on a regular basis, to just use those up until they're gone. Remember, you are not allowed to just throw them away! Any unused 222's would need to be returned to the DEA anyway, so you might as well just use them instead.
3. The Workflow
1. The Purchaser makes a copy of the form and mails it to the supplier. They keep the copy, and then log the receipt of each item on their copy, just as they would with the old 222s, and file it away.
2. The Supplier fills out the rest of the information (the info a supplier would fill out on the old forms) and mails you the drugs.
3a. If The Supplier reports to ARCOS (the distributor version of a PDMP), they keep the original, and they're done.
This would be essentially only be true wholesalers, though there might be the rare pharmacy that does enough wholesaling to report to ARCOS, in which case they can keep the original.
3b. If The Supplier does not report to ARCOS, they either mail a copy of the form (don't send them the original!) to the DEA or email it to DEA.Orderforms@usdoj.gov. I personally like the idea of email because it's 100% traceable - the DEA could never say you didn't do it. Also, they want it done by the end of the month you ordered in.
3b would be you if you send returns back to your wholesaler, transfer C2's to another store, etc. (and you don't report to ARCOS, of course).
If you work for the DEA and are reading this, we appreciate you making our life a little easier in the pharmacy. Next, maybe you'll stop making us archive CSOS forms on our computer, even though we have both printed invoices and can access them anytime on our distributor's website, who also happens to report the exact same transaction to you through ARCOS?
Maybe that's too much to ask...
Keywords: DEA, CSOS, DEA 222, purchaser, supplier