West Virginia MPJE (Pharmacy Jurisprudence) Practice Exam

Is a DEA 222 form required if drug products are transferred from a central fill pharmacy to its retail pharmacy?

1. No

2. Yes

3. Only if the quantity exceeds 100 units

4. Only if the product is a CII drug

The correct answer is: No

The correct answer is that a DEA 222 form is not required when drug products are transferred from a central fill pharmacy to its retail pharmacy. This is because the transfer of controlled substances between pharmacies that are acting as a common entity (such as a central fill pharmacy and its retail counterpart) does not typically necessitate the use of a DEA 222 form, which is specifically required for the sale or transfer of Schedule II controlled substances between separate entities. In instances where a central fill pharmacy dispenses a prescription, it is still considered a single operation under the same ownership structure for regulatory purposes. Therefore, the movement of products between these two entities does not invoke the same requirements as a sale between two independent pharmacies. The requirement for a DEA 222 form is generally directed towards transfers between unconnected pharmacies or businesses, aimed at maintaining strict control over the distribution of controlled substances, particularly those in Schedule II. Thus, the focus on regulatory compliance ensures that proper records are maintained, but does not necessitate a 222 form for internal transfers between affiliated pharmacies.