This template is for recording employer compliance with CFR 1301.91.  The copy of the CFR can be found at the DEA Website.  The ‘original’ can be found at the GPO Website.

The template, in an editable Word 97 format is located here.

Note:  I am not a lawyer.  I make no guarantees as to how well this will CYA (Cover Your Organizations Assets).

Before implementing this compliance tracking tool, may I suggest management and labor discuss this with input from their respective councils.

Be sure your organization’s OP’s/AP’s/SOP’s (How ever your organization refers to them) defines or spells out the following items:

Drug Diversion

Narcotic Tampering

Responsible Security Official

Procedures, time frame and identify the responsible parties to make notification to the Medical Director, DEA and local law enforcement

Procedures for handling an internal investigation if necessary

How the identity of the accused*(if any), the accusation and informant will be kept confidential

Punishment for breach of confidentiality (for releasing the accused’s or informant’s information)

*Diversion/Tampering may be discovered without a chief suspect

NEW 3/28/11

Position Paper Template for your use at your agency to implement the usage of CFR 1301.91 in your organization.

Letter of Compliance example from San Juan Island EMS.