Narcotic Treatment Programs Best Practice Guideline
The following sections summarize procedures related to the receipt of the medication from the supplier, including the designation of NTP personnel responsible for receiving and storage of the medication, and procedures to be followed when a discrepancy or damage is identified at the time of delivery.
Federal regulations require that medication deliveries to an NTP be received and secured by program personnel specifically designated for these tasks. Acceptance of delivery of narcotic substances must be made only by a licensed practitioner employed at the NTP or by other authorized individuals designated in writing (excluding persons currently or previously dependent on narcotic drugs), who must sign for the narcotics. [21 CFR 1301.74(h)]
- It is recommended that the NTP designate one staff member to have primary responsibility for receiving and securing the medication. The NTP also should identify additional program personnel who have authority to receive and store the medication at times when the individual designated to have primary responsibility is not available.
- The NTP must maintain a written list of all designated personnel who have been authorized to receive and store the medication. [21 CFR 1301.74(h)].This list should be updated whenever a change in designated personnel occurs.
When a shipment of the medication is delivered to the NTP:
- At the time of delivery, the designated staff member who receives the shipment should count the number of bottles in the shipment immediately and compare that number with the number found on the invoice.
- The designated staff member who receives a particular shipment should sign for the shipment only after all of the ordered medication has been accounted for.
- If there are no discrepancies or damage and the medication is accepted as delivered, the designated staff member receiving the shipment must complete the right-hand column of Copy 3 of the DEA Form-222 that the NTP originally completed for the order, indicating the date of the delivery and the quantity received. [21 CFR 1305.09(e)].
- It is recommended that NTP personnel who have been designated to receive shipments of medication initial the right hand column of the DEA Form-222, upon receipt of the medication.
- The NTP must retain Copy 3 of all completed order forms as part of the program's records of receipts. [21 CFR 1305.13(a)].
- Order forms must be maintained separately from all other records and must be retained at the registered location for two years after the date of execution [21 CFR 1305.13(c)], or for the length of time required by the State Methadone Authority, whichever is the stricter requirement.
Procedures to be followed when a discrepancy or damage is found by the designated NTP staff at the time of delivery include the following:
- When all or part of a shipment disappears, or never reaches its intended destination, the supplier is responsible for reporting any in-transit losses of controlled substances to DEA. An NTP is responsible for reporting any losses of controlled substances after a designated staff member has signed for and taken custody of a shipment. [21 CFR 1301.74(c)].
See the section entitled "Reporting Thefts and Losses of Controlled Substance Medication," in Part 6, "Recordkeeping," which discusses the filing of DEA Form-106, "Report of Theft or Loss of Controlled Substances."
- If, when checking a shipment at the time of receipt, the designated staff member receiving a shipment determines that there is a discrepancy between the amount of medication received and the amount ordered (i.e., a discrepancy that has not been explained by the supplier on the invoice included with the delivered order), the staff member should contact the supplier immediately for further instructions.
- When the designated staff member receiving a shipment determines that there has been damage to the medication, the staff member should contact the supplier immediately.
- The supplier should contact the appropriate DEA office immediately after being notified by the NTP of a discrepancy or damage found in a shipment.
- The supplier should contact the NTP to advise the program of the final determination regarding the discrepancy or damage.
- The NTP should document the discrepancy or damage to the shipment, related actions taken, and the final determination, which should be attached to Copy 3 of the relevant order form.