DEA registration, Form 222 ordering, biennial inventory, theft/loss reporting, CSOS, POA — everything tested on the MPJE about DEA regulations.
Every pharmacy and individual practitioner who handles controlled substances must be registered with the DEA. Understanding the registration process, required forms, and practitioner authority levels is essential for the MPJE.
| Form | Purpose | Key Details |
|---|---|---|
| DEA 222 | Order Schedule II controlled substances | Triplicate (or CSOS electronic). Max 10 items per form. POA may sign. Voided forms retained. Executed forms kept 2 years. |
| DEA 41 | Controlled substance inventory | Biennial (every 2 years). CII = exact count. CIII-CV = estimated count (exact if container opened). Record date, time, and whether opening/closing inventory. |
| DEA 106 | Theft or significant loss report | File upon discovery. Also notify local DEA Diversion Field Office. Must include description of loss and substances involved. |
| DEA 224 | New DEA registration | For new registrants (pharmacies, practitioners). Submit with fee. Processing takes several weeks. |
| DEA 224a | DEA registration renewal | Submit before expiration. Must not dispense CS if registration has lapsed. |
| CSOS | Electronic ordering for CII (replaces DEA 222) | Controlled Substance Ordering System. Digital certificate required. Same regulatory requirements as paper DEA 222. |
A registrant may authorize another individual to sign DEA 222 forms on their behalf through a Power of Attorney. The POA must be filed with the pharmacy's DEA records and is revocable at any time. The individual signing does NOT need their own DEA registration — they are acting under the registrant's authority.
Nurse practitioners, physician assistants, and other mid-level practitioners may prescribe controlled substances if authorized by their state AND registered with the DEA. Their DEA number begins with the letter M. The MPJE may test whether a specific MLP type can prescribe CS in a given state — always check your state's specific scope of practice laws.