AS I SEE IT


Options for Controlled Drug Registration What ASCs need to know BY SHELDON S. SONES


When an ASC’s controlled drug license is set to expire and requires renewal, the surgery center has options for the go-forward “reg-


istrant” designation. This also can be the case if the assigned registrant on the license—usually the ASC’s medi- cal director—changes, since a change of that kind also prompts a re-registra- tion. As an aside, whoever the current registrant is, the address that should be used is the location of the facility, not the one used for the registrant’s per- sonal, licensed office practice. One option is for the ASC’s medi- cal director to accept responsibility for controlled drug management and record keeping. This is the model I usu- ally encounter in facilities. Again, this is a separate license not correspond- ing to the medical director’s practice registration and location. Before the assignee accepts this responsibility, I recommend that they review and accept a thorough description of the process. The registrant then has the option to assign a power of attorney (POA) to one or more licensed individuals to enable the ordering process. This is the process I see most ASCs follow. The Drug Enforcement Administra- tion (DEA) has a suggested format for this POA at https://www.deaecom. gov/poa.html. The singular disadvan- tage of this model is the need to re- register, paying any associated license fees, if the medical director or other physician who has accepted this role should change. The second option is for the facility


to register in the name of the facility. The advantage of this model is that if the medical director or other assigned registrant should change, the facility is


I recommend that you work with your pharmacy consultant to assure that both federal and state requirements are met adequately.”


—Sheldon S. Sones, Sheldon S. Sones and Associates


not required to re-register. The ASC’s administrator can grant the POA and retain responsibility for the process of controlled drug management. It is important to note that whole- salers that provide controlled drugs will request a copy of your ASC’s licensure as well as the POA. This request is appropriate, and those documents should be provided and updated as any changes occur. I also recommend that whenever the desig- nated POA or registrant changes for some reason, including a change in that person’s position or a decision to terminate their employment or associ- ation with the facility, the exiting indi-


vidual and the new assignee should document a controlled drug count. A copy should be retained by the exiting individual as a final attestation of the actual counts. Finally,


it is important to note


that most states have a requirement for controlled drug licensure for the state. I recommend that you work with your pharmacy consultant to assure that both federal and state requirements are met adequately.


Sheldon S. Sones is the president and founder of Sheldon S. Sones and Associates in Newington, Connecticut. Write him at Shelsones@aol.com.


The advice and opinions expressed in this column are those of the author and do not represent official Ambulatory Surgery Center Association policy or opinion. 8 ASC FOCUS AUGUST 2020| ascfocus.org


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