DEA Controlled Substance SOP for Texas Veterinary Practices

Registration and licensing

Texas requires no separate state controlled-substance registration. Texas eliminated its state controlled substances registration effective September 1, 2016: the state-registration subsections of Health and Safety Code §481.061 were repealed by S.B. 195 (2015), and the section — now titled "Federal Registration Required" — provides that a person "registered with or exempt from registration with the Federal Drug Enforcement Administration" may handle controlled substances in Texas to the extent the DEA registration authorizes. Your DEA registration is the only controlled-substance registration this practice needs. The Texas Board of Veterinary Medical Examiners (TBVME) rule on point simply requires compliance "with all requirements of the federal Drug Enforcement Administration (DEA) regarding controlled substance registration" and with related state and federal law. ^{1 2}

Storage standard. TBVME requires all Schedule I–V stock to be "stored in a securely locked, substantially constructed cabinet or security cabinet" and bars access to CS storage areas "except those authorized agents required for efficient operations". Apply this standard in the storage and security section. The rule text as archived also requires a written list of all persons with access to CS storage areas, with the dates individuals are added or removed — keep the access list current. ^{3 4}

Inspections. TBVME conducts unannounced, risk-based inspections of a veterinarian's controlled-substance handling and may examine and copy drug records, invoices, inventory logs, and surgery logs. Keep this SOP and its logs inspection-ready at the practice. ⁴

PDMP or reporting duties

Reporting when you dispense: Texas places Prescription Monitoring Program (PMP) reporting duties on pharmacies, not on veterinarians. The statute requires "each dispensing pharmacist" to send dispensing data to the Texas State Board of Pharmacy by the next business day; the board's rule implements this as a pharmacy duty, and the board states that "all Texas-licensed pharmacies are required to report all dispensed controlled substances records". A veterinarian dispensing from clinic stock in the course of practice is not a pharmacy and is not required to report those dispensations to the Texas PMP — but must keep the dispensing records required by this SOP and by TBVME rule (see the records-retention section). ^{5 6 7 8}

Checking before prescribing or dispensing: veterinarians are expressly exempt from Texas's mandatory PMP check. The duty to review a patient's PMP history before prescribing or dispensing opioids, benzodiazepines, barbiturates, or carisoprodol applies to persons authorized to access the PMP "other than a veterinarian". ^{9 7}

Voluntary access: a veterinarian may query the PMP, but "only for the animals of an owner and may not consider the personal prescription history of the owner". ⁹

Records, inventory, and retention

Controlled-substance records — 5 years. Texas veterinarians "shall maintain at their place of business records of all scheduled drugs listed in the Texas Controlled Substances Act in their possession. These records shall be maintained for a minimum of five years." The record must be per-drug, "complete, contemporaneous, and legible," and show date of acquisition, quantity purchased, date administered or dispensed, quantity administered or dispensed, client and patient name, and a running balance on hand. The CS log in this kit captures all six elements — keep completed logs, invoices, and inventories for five years, not the federal two. ⁸

Patient medical records and radiographs — 3 years after the last visit; TBVME's inspection standards (22 TAC §§573.52/573.53) require individual records to be "maintained at the veterinarian's place of business" and to be complete, contemporaneous, and legible. ^{10 11 4}