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DEA enforcement in long-term care: is a collaborative correction feasible?
Rebecca D Elon1, Claudia Schlosberg, Steven Levenson
1Johns Hopkins University School of Medicine, Gilchrist Hospice Care, Lorien Columbia Health Care Center, 6334 Cedar Lane, Columbia, MD 21044, USA. relon@gbmc.org
Journal of the American Medical Directors Association
|April 30, 2011
Summary
Controlled substance management in long-term care facilities requires improved processes. Current Drug Enforcement Administration enforcement strategies are suboptimal, necessitating legislative and regulatory revisions for better patient care and diversion prevention.
Area of Science:
- Public Policy
- Clinical Pharmacy
- Regulatory Affairs
Background:
- Controlled substance prescribing and dispensing in long-term care facilities (LTCFs) present complex clinical and public policy challenges.
- Current Drug Enforcement Administration (DEA) enforcement strategies, implemented since 2009, are suboptimal for institutional pharmacies serving LTCFs.
Purpose of the Study:
- To review the regulatory background and clinical concerns of DEA enforcement of the Controlled Substances Act in LTCF pharmacies.
- To argue that existing post-2009 processes are inadequate and propose a collaborative, multi-faceted solution.
Main Methods:
- Review of regulatory background and clinical concerns.
- Analysis of current enforcement processes and their impact.
- Policy framework development and proposal of a collaborative resolution process.
Main Results:
- Current processes are suboptimal, failing to adequately balance patient needs, diversion prevention, clinician burden, and regulatory compliance.
- A robust solution requires collaboration among stakeholders to address legitimate, yet competing, agendas.
Conclusions:
- Optimal outcomes necessitate legislative amendments to the Controlled Substances Act and regulatory revisions.
- An ongoing, collaborative process is essential for resolving the complex issues surrounding controlled substance enforcement in LTCFs.
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