Who’s Afraid of the DEA?
Cathy A. Gallagher, BS, associate section chief of the Liaison and Policy Section of the Drug Enforcement Agency’s (DEA’s) Office of Diversion Control offered the DEA’s perspective on the handling of controlled substances at the Monday morning General Session.
Gallagher began her presentation by stating the mission of the Office of Diversion Control, which is “To prevent, detect, and investigate diversion of controlled substances from legitimate sources while ensuring an adequate and uninterrupted supply for legitimate medical and scientific purposes.” She stressed the importance of the second part of the mission, “What people don’t really know is that we have the other component where we need to ensure that there’s adequate supply for legitimate practice and scientific purposes,” and explained that the DEA stresses balancing the control of diversion with the provision of adequate supply.
The presentation focused on the requirements of the Controlled Substances Act of 1970 (CSA), a consolidation of over 50 laws regulating the manufacturing, distribution, import and export, and dispensing of controlled substances and listed chemicals. Gallagher described the five schedules of controlled substances, which categorize drugs according to their levels of accepted medical use and abuse potential. The CSA created a closed system of distribution for controlled substances maintained through registration, established schedules and quotas, security and recordkeeping requirements, the Automation of Reports and Consolidated Orders System (ARCOS), and cyclical investigations. “In theory, the goal is that there would be no diversions,” Gallagher said.
Gallagher emphasized that “Recordkeeping is the key to everything,” and that a legal prescription for a controlled substance is 1.) Written by a licensed practitioner, 2.) For a legitimate medical purpose, and 3.) In the usual course of practice (i.e., Would your peers do the same?). She also emphasized that the DEA does not define medical practice standards, put limits on quantities of drugs prescribed, apply greater scrutiny to the prescription of controlled substances, or put anyone “on the list” of patients who cannot be prescribed certain medications.
Other topics discussed in the speech and the question-and-answer session that followed included electronic prescriptions, security, pain management policy, methods of diversion, and disposal of expired and unused medications.
Although the perception of the agency as “Big Brother” tends to instill fear, Gallagher assured the General Session audience that they have no reason to be afraid of the DEA.