Several aspects of the proposed BOP guidance seem out of step with The DEA's proposed rules on the amended Controlled Substances Act. Perhaps waiting for the DEA's rules to be finalized prior to writing the BOP guidance document should be considered to prevent having differing guidance published.
Some examples:
DEA rules have proposed:
-permitting storage in facilities without requiring a separate registration for each individual site (e.g. firehouse)
-allowing one for one medication exchange with a hospital following a patient care episode even if the EMS agency's primary routine means of medication handling is agency-based.
In section II of the BOP document, EMS Preparation of its Own Kits Model:
Storage of Schedule II-VI Drugs within EMS Facility for Preparation of Drug Kits:
"Under this model, the EMS facility is solely responsible for preparing and securely storing drug kits for its own use, and replacing drugs within the kits as used for patient administration. The EMS agency does not exchange kits or drugs with a hospital pharmacy."
This prohibition of 1 for 1 exchange at the hospital appears out of step with what DEA is proposing (establishing routine handling of medications by EMS agency but still allowing one for one after an emergency incident with transfer of custody).
From the DEA's proposed rules amended Controlled Substances Act:
Section E.1.a. Restocking
"Following an emergency response where controlled substances were administered, EMS personnel may not have enough time to return to their stationhouse to restock their EMS vehicle with controlled substances. Depending on the circumstances, the stationhouse may be a considerable distance from the hospital where the EMS personnel brought a patient, or the volume of emergencies may be so great that the ambulance does not have time to return to the stationhouse. Rural EMS systems in the United States may face transport distances of 20 to 100 miles to the nearest hospital. Thus, the Act allows non hospital-based EMS agencies to receive controlled substances from a hospital for the purpose of restocking an EMS vehicle following an emergency response."