On February 21, 2019, the Drug Enforcement Administration (DEA) published a Notice of Proposed Rulemaking (NPRM), New Single-Sheet Format for U.S. Official Order Form for Schedule I and II Controlled Substances (DEA Form 222).  This is the agency’s second attempt at bringing the DEA Form 222 into the 21st Century.  In 2007, the agency issued a similar NPRM, but never published a Final Rule.

The current NPRM not only changes the format of the 222, but also proposes “minor procedural changes.”  Below is a summary of some of those changes.

Format of the new form

  • Single sheet form, with enhanced security features and printed on special paper to “ensure the identity of the original.”
  • New forms will no longer be issued in “books” but will be issued in a predetermined amount depending on business activity.

Procedures for executing single sheet 222 forms

  • New forms will be processed in a manner similar to what is currently required.
  • A purchaser will fill out the form and send the original form to its supplier. The purchaser must retain a copy of the 222 form in a readily retrievable manner and is allowed to copy/scan and store the form electronically.
  • The supplier must retain a copy of the original form and does not have to submit the form to the local office or DEA HQ, if the supplier reports to ARCOS.
  • Any “registrant supplier” who is not required to submit an ARCOS report (such as a practitioner) will be required “to make and submit a copy of the original DEA Form 222 to DEA [HQ] by mail, fax, or email.”
  • Forms will no longer be sent to the local office.

DEA is also proposing a change regarding who is authorized to issue a Power of Attorney (POA) for executing 222s.  Currently, only the registrant may issue a POA.  Under the proposed rule, a POA can be executed “by the registrant, if an individual; by a partner of the registrant, if a partnership; or by an officer of the registrant, if a corporation, corporate division, association, trust or other entity…”

I applaud DEA’s efforts to modernize the DEA Form 222 and hope that similar efforts are ongoing with respect to applying for, obtaining, and renewing CSOS credentials.  Those wishing to comment on the proposed rule must do so within 60 days of publication of the NPRM.

As a side note, I believe this marks the final death blow to the dot matrix printer and carbon forms printed on interleaved carbon sheets.   It is a sad day….


*Photo by Christa Dodoo on Unsplash