Diversion Control Division, US Department of Justice, Drug Enforcement Administration

Narcotic Treatment Programs Best Practice Guideline

APPENDIX A

ANSWERS TO FREQUENTLY ASKED QUESTIONS

Recordkeeping


Question: The state requires that I maintain records for three years, but DEA only requires two years. How long must I maintain records?

Answer: You must follow whichever requirement is stricter. In the example cited above, you would be required to maintain records for three years.


Question: Our program had some computer problems and lost some data. What should we do?

Answer: Any problems that involve loss of data should be recorded in writing to document any unusual occurrences. This documentation should be signed by those witnessing the incident. If it was possible to reconstruct the data using sign-in logs and other back-up documents, this should be mentioned in the incident report. The program should maintain a separate incident report file to be presented to investigators upon request. To reduce data loss in the future, your computer records should be backed up regularly using procedures recommended by your computer software supplier, so that only a minimal amount of data will be lost.

However, the loss of data should be minimal (no more than one day) as each NTP is required to maintain medication dispensing records in a dispensing log as outlined in 21 CFR 1304.24(b). Even those NTPs that use an automated/computerized data processing system for maintaining, storing, and retrieving dispensing record information are required to print a hard copy of each day’s dispensing log, which is then initialed by each person who dispensed medication to patients. See Part 6, Recordkeeping, the section entitled "Dispensing Records" for additional information.


Question: Must we use patient names on dispensing records?

Answer: No. You may use patient identification numbers and maintain an up-to-date cross-index that associates each identifying number with the name and address of the person to whom it refers.

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