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Drug-Use Reviews

The majority of respondents who personally favor peer review thought drug-use reviews are appropriate but require active association support, 31 percent (57). It appears that very few respondents oppose (i.e., objection, moderate acceptance, or unobtainable) drug-use reviews in any form. Dentists were divided on whether the reviews needed active support, 25 percent (5), or would receive moderate acceptance, 35 percent (7).

Almost all responding physicians, MDs, 80 percent (12), and pharmacists 76 percent (32), expressed the need for active association support for drug-use reviews. The majority of responses indicated that the State association should participate in the drug-use reviews. However, there was also considerable support, especially by the dentists for State professional boards conducting the review. The tendency appears to be away from both the national association and Federal Government levels.

(6) Drug-Related Continuing Education

There is apparently little activity among the States in continuing education on drug abuse by health care practitioners or patients, or controlled substances abuse in general. This may reflect a lack of interest as well as the difficulties involved in obtaining good programs. However, it is recommended that serious consideration of development of regional continuing education programs and joint continuing education programs involving smaller States with larger States if specialized programs on drugrelated issues are to be presented effectively.

References

1. Kernodle, John R., (Chairman), "Physicians with Psychiatric Disorders including Alcoholism and Drug Dependence," Reports to the Board of Trustees: (C-72) Chicago, AMA, (1972). 2. Turner, Richard K., "The Physician Addict: Law, Licensure, and Rehabilitation," Fed. State Medical Boards Bulletin, Vol. 56, pp. 142-148 (June 1969).

3. Letters to the Editor, American Dental Association News, Vol. 5, No. 23, p. 2, (Nov 18, 1974).

VII. Voluntary
Compliance
Policies

Chapter V, Compliance and Enforcement Investigations, included a discussion of the responsibilities of Federal, State, and Local enforcement agencies in controlling the sources of drug diversion at the retail level. This chapter discusses voluntary compliance policies at the retail level.

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*Editor's Note: Effective September 3, 1976, the Regulatory Investigations Section was reorganized within the new Office of Compliance and Regulatory Affairs (CR) and is now the Investigations Section of the Compliance Division within CR. **Editor's Note: Effective September 3, 1976, the Attorney General approved the new Office of Compliance and Regulatory Affairs. The new Office combines the functions of the former Compliance Investigations Division which was under the Office of Enforcement and the Special Programs Division under the Office of Science and Technology (less the Special Studies Section and contract research function of the Special Programs Division). The new Office has three divisions. These are: Regulatory Support, Compliance, and Regulatory Control.

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These are legal notifications to a registrant that some aspect(s) of his practice is (are) not acceptable to the DEA. This action has been taken in 194 cases. Letters to Type A registrants comprised 28 percent of these cases.

Administrative and Show-Cause Hearings These hearings are held when the severity of the violation and the registrant's attitude are such that a letter of admonition will not achieve compliance.

• Suspension of Registration

Suspension of registration may be imposed until corrective action has been completed and/or a specific time period has elapsed. Revocations/Denials

The DEA Administrator may deny registration to dispense controlled substances to a registrant or applicant (excluding practitioners) if the registrant is operating under conditions which conflict with the public interest.

• Surrender of Registration

Voluntary surrender of registration may occur when a registrant does not wish to contest the DEA action.

2. ALTERNATE FORMS OF CONTROL

A major alternative form of control at the retail level is the Diversion Investigative Unit (DIU). Through application to the Law Enforcement Assistance Administration (LEAA) of the Justice Department, several States have assembled ad hoc task forces to address the problem of drug diversion at the retail level. This form of control constitutes a more active approach to the diversion problem by State agencies.

The DEA initiates the formation of a DIU in those States which meet the following criteria:

• A commitment by State agencies and professional groups to combat the problem of drug diversion

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