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 and its lines

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

The Line items section takes the numbered lines as they appear on the paper form: number of packages, package size and unit, and the name of the item. 1305.12(b) allows only one item per numbered line, so add a line per item rather than combining them. Add another line adds a row and each row past the first can be removed. Lines left completely blank are ignored.

Package size and number of packages stay separate everywhere in CS Logbook, because 1305.21(b)(8) asks for the quantity in a single package and (b)(9) asks for how many packages were ordered. Three bottles of 250 mL is 3, 250, mL, never 750.

Strength, NDC and per-line notes are not on this form. Fill them in on the order's own page once it is saved, where every field of a line can be changed, and add any line you missed there too.

Step 3: Mark it executed, then record what the supplier did

An order starts as a draft. Mark executed when the purchaser has signed and dated the paper form (1305.12(d)). Entering that date is optional but useful: a DEA Form 222 is valid for 60 days from execution (1305.13(b)), and CS Logbook can only tell you an order has expired if it knows when it started.

Record supplier disposition covers what happened after the form left your clinic. A supplier may decline to fill an order, or find it defective. 1305.17(a) asks you to keep those forms with the supplier's statement attached, which you can upload from the order's page.

Your paper Form 222 is the DEA record. What CS Logbook holds is your own log of it, so nothing here locks. If you record the wrong status, change it: use Edit to set any status, or the same buttons again. Every change is saved with who made it and when, and you can add a note explaining why. A void does not need a reason, though adding one makes the log easier to follow.

Removing an order takes it out of your logbook. The record and its history stay in the database, but you will not be able to reach it from the app again, and your paper form is unaffected.

Step 4: Record what arrived

Add receipts against the order's line items as stock arrives. 1305.13(e) puts this duty on the purchaser: you record, on your own copy, how many containers were furnished on each item and the date they arrived. A supplier may fill an order in part and ship the balance inside the 60-day window, so a line takes as many receipts as it needs. Quantities are stored as you state them rather than calculated, because what you wrote on your copy is the record.

The receipt form asks for two different numbers:

• Packages received is how many bottles or packages of that line arrived in this shipment. This is the count a paper Form 222 asks you to write down. If you ordered 3 bottles of 250 mL and all 3 arrived, enter 3.
• Total quantity received is the total amount of drug in the shipment, in the line's unit. For the same 3 bottles of 250 mL, enter 750. A CSOS electronic order records this figure.

Either can be left blank if you do not have it to hand. If the packages recorded across a line's receipts add up to more than the line ordered, the form shows an amber note, and you can still save.

You can also link the supplier's invoice for the shipment. Pick the supplier (the order's supplier is chosen for you), then the invoice. If the invoice is not listed yet, create it from the picker or on the Invoices tab. Choosing a different supplier's invoice is allowed and shows an amber note. Use Notes for anything irregular: damaged, short or substituted packages, a backorder the supplier will ship later, or who received the shipment.

Correcting a line or a receipt

Every line item and every receipt can be corrected on the order's page, at any status, including an executed order. Select a value to change it: the line number, the item name, strength, NDC, number of packages, package size, unit and notes on a line, and the date received, packages received, total quantity received and notes on a receipt. Blank a value to clear it.

Each change is saved with the old value, the new value, who made it and when, and it appears in the change history report. Each field also offers a box for the reason. A reason is recommended, never required: the change saves without one. The substance a line is linked to and the invoice a receipt is linked to are not changed here.

Step 5: Receive the containers

The receipt is your loading-dock record. The bottles themselves go into inventory as containers, and you can do that straight away or later. Each receipt on the order shows a Receive containers link until every package it records is linked. The link opens bulk receive with one row per package still to enter, already filled in with the substance, package size, unit, date received, supplier and invoice from the order and the receipt. Check each row against its label, add the lot number and expiry, and save. The containers are linked to that receipt, and you return to the order form.

If the order line did not name a substance from your formulary, or its unit is not one containers use, the form tells you and leaves that field for you to choose. A missing lot number or invoice does not stop you saving; each is flagged in amber so you can complete it later.

Once containers are linked, the receipt compares them with what you recorded and flags a difference in amber: a different number of containers than packages received, or a different total quantity when the units match.

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, linked from each receipt