Inventory → Order forms

Purpose

Keep the copy of every DEA Form 222 or CSOS electronic order your clinic executes to buy Schedule I or II controlled substances, together with what was received against it.

Regulatory basis: 21 CFR 1305.17(a) requires the purchaser to retain a copy of each executed form, and 1305.17(c) requires those copies be kept "separately from all other records of the registrant" and available for inspection for two years. 1305.27 says the same for electronic orders.

CS Logbook stores and organizes the record. It does not order anything, does not submit anything to DEA, and does not decide whether your paperwork is adequate. Every field on the form is optional and nothing is ever blocked, so you can record what you have now and finish it later.

What goes in each field

The four fields below are the ones people ask about, because the answer differs between a paper form and a CSOS order.

Form number

Paper Form 222: the number DEA printed on the form. You do not choose it and you cannot change it. 21 CFR 1305.11(d): "DEA Forms 222 will have an order form number and be issued with the name, address and registration number of the registrant, the authorized activity, and schedules of the registrant. This information cannot be altered or changed by the registrant."

CSOS: the number you assign. 1305.21(b)(1) gives the shape: "A unique number the purchaser assigns to track the order. The number must be in the following 9-character format: the last two digits of the year, X, and six characters as selected by the purchaser." So an order placed in 2026 might be 26X000147.

If you enter a CSOS number that does not match that shape, an amber note appears and the value is still saved exactly as you typed it. You may be transcribing from a system you do not control, and the record of what it actually said matters more than tidiness.

This is not the supplier's invoice or purchase-order number. Record that on the invoice.

Date executed

The date the form was signed, not a date printed on it and not the date it was mailed.

21 CFR 1305.12(d): "Each DEA Form 222 must be signed and dated by the registrant, if an individual; a partner of the registrant, if a partnership; or an officer of the registrant, if a corporation, corporate division, association, trust or other entity; or a person granted power of attorney to sign a DEA Form 222 under § 1305.05." For a CSOS order the same value is the data field 1305.21(b)(6) calls "The date the order is signed."

This date drives the validity note on the page. 1305.13(b): "No DEA Form 222 is valid more than 60 days after its execution by the purchaser." Past 60 days an amber note appears. You can still record receipts against the order, because stock that physically arrived is a real event and has to be recordable either way.

Where it is filed

Plain text describing where the retained copy lives, for example DEA binder, cabinet 3 or shared drive, Controlled Substances/222.

This field exists because order forms are filed apart from everything else. 1305.17(c): "DEA Forms 222 must be maintained separately from all other records of the registrant." A central-records arrangement does not cover them either, per 1304.04(b)(1). If you keep electronic copies, 1305.17(e) allows them to sit on a system somewhere else "provided such copies are readily retrievable at the registered location", which is exactly what this note should tell whoever goes looking.

Recording a paper copy is a complete answer. Attaching a scan is optional.

Signed by

Whoever actually signed. Per 1305.12(d) above, that is the registrant, a partner or officer, or someone holding a power of attorney under 1305.05.

The signer does not have to be a veterinarian, and does not have to work at the registered location. 1305.05(a) lets a registrant authorize "one or more individuals, whether or not located at his or her registered location" to sign. So the picker lists your whole staff roster, and you can type a name that is not on it at all. A DEA badge appears next to staff who hold a current practitioner registration, as information only. It never filters the list.

If the signer is not the purchaser, 1305.12(d) requires both names on the form: "The name of the purchaser, if different from the individual signing DEA Form 222, must also be inserted in the signature space." That is why Signed by and Purchaser DEA number are separate fields here.

Filling the form faster

Three pickers fill the text fields for you. Each one writes into an ordinary text box that you can then edit, because what is stored is what your form said, not what your records say today.

• Supplier on file fills the supplier's name, DEA number and address from your Suppliers list. 1305.12(c): "The name and address of the supplier from whom the controlled substances are being ordered must be entered on the form. Only one supplier may be listed on any form. The supplier's DEA registration number may be entered by the purchaser or the supplier." If the supplier record has no DEA number, an amber note links you to the record so you can add it. Nothing is blocked in the meantime.
• Fill from a registered veterinarian fills the purchaser DEA number from that person's practitioner registration. A DEA registration belongs to the individual veterinarian, not to the clinic, so this reads from their license record.
• Fill from the staff roster fills the signer's name.

Editing an existing order never rewrites these values on its own. If you open an order from two years ago and its supplier has since moved, the address you recorded then stays put. That is the point of keeping them: 1305.11(d) and 1305.12 describe a form whose contents were fixed at the moment it was executed.

Registered location on the form

Defaults to your clinic's address on a new order, and is editable. It is the registered location DEA printed on the form, which matters if your practice holds more than one registration: 1305.17(c) says a purchaser with several registered locations keeps the copy "at the registered location printed on the DEA Form 222."

Walkthrough

Step 1: Open the list

Go to /home/<your-clinic>/inventory/order-forms. Before you have recorded anything, the page offers Record Order Form and Powers of Attorney.

Step 2: Record the order

Record Order Form opens the full form. Nothing is required. Set the format first, since it changes what the form number means.

Step 3: Mark its disposition

An order starts as a draft, which can still be discarded. Once you mark it executed it becomes a retained record and can no longer be deleted, only amended with a reason or voided. That mirrors 1305.17, which requires the record be kept rather than frozen. Unaccepted and defective forms are retained too, per 1305.17(a).

Step 4: Record what arrived

Add receipts against the order's line items as stock arrives. Quantities are stored as you state them rather than calculated, because what you wrote on your copy is the record.

Powers of attorney

If someone other than the registrant signs your orders, 1305.05(a) requires the power of attorney be retained "for the same period as any order bearing the signature of the attorney" and be "available for inspection together with other order records". Record them under Powers of Attorney and link them to the orders they cover. A revoked power of attorney stays linked to the orders it signed, which is deliberate.

Related

• Suppliers, where supplier DEA registration numbers are kept
• Invoices, the document side of what arrived
• Containers, the stock received against an order