Vets told to register with California’s CURES; board details reporting, recordkeeping and inspection expectations

A recent webinar hosted by the California Veterinary Medical Board advised veterinarians that registration with the state’s prescription drug monitoring program (CURES) is mandatory for any veterinarian who holds a California license and a DEA registration and that practices must keep records showing compliance.

The Department of Justice’s Amber Davidson, who identified herself as being with the Department of Justice CURES program, described CURES — “the controlled substance utilization review and evaluation system” — and the system’s scope and reporting rules. Dr. Jim Howard, a representative of the Veterinary Medical Board, outlined what inspectors will look for on site and emphasized that inspections are primarily educational.

Why it matters: The guidance affects how veterinary practices order, dispense and document controlled substances and what evidence inspectors will expect during visits. Failure to maintain required logs, inventories or CURES reporting could lead to follow-up from the board and, in some circumstances, enforcement by federal authorities.

CURES scope, registration and reporting

Amber Davidson said CURES contains prescription dispensing records for schedules II through V and that the system “contains about 750,000,000 records” and receives roughly 700,000 prescriptions each week. She advised veterinarians that if they hold both a California license and a DEA registration they must register with CURES as prescribers; practices that directly dispense controlled substances must report dispensations to CURES as dispensers.

Davidson summarized key statutory reporting points cited during the webinar: Health and Safety Code reporting provisions differ by dispenser type; reporting under the provision that applies to dispensing by prescribers (cited in the webinar as Health and Safety Code §11190(c) referencing Business and Professions Code §4170) requires weekly electronic submission of specified fields for dispensations made by prescribers pursuant to BPC 4170. She also noted limited exceptions: direct administration to the body of an ultimate user is not reportable, and short supplies (quantities to treat 48 hours or less) follow alternative reporting timing in the statute as described in the presentation.

Davidson explained practical points for veterinarians using CURES: the system’s patient-activity search for veterinarians is centered on the animal owner (human last name, first name and date of birth) and that veterinarian dashboards show animal-dispensation records when species is recorded as an animal. She described delegate access: authorizing users may add delegates who meet regulatory criteria and must execute a delegate agreement; delegate functionality and responsibilities are described in the CURES regulations (California Code of Regulations, Title 11, Article 2.4).

Timing and vendor details

Davidson said veterinarians have seven days to submit dispensations to CURES (a longer period than most other health-care providers, who must report within one business day) and that Bamboo Health is the current data vendor used by the Department of Justice CURES system. She reminded attendees that manual submission via the universal claim form (UCF), secure file transfer or vendor software are acceptable submission routes and that a practice may submit “0-fill” reports but is not required to do so.

Recordkeeping, security and inspections

Dr. Jim Howard told viewers that board inspections focus on education and compliance rather than seizure or pill counts. “The primary goal of the inspection process, again, is education,” he said, adding that inspectors will ask practices to show records demonstrating CURES submissions and proper controlled-substance inventories. He said inspectors typically are veterinarians or registered veterinary technicians with recent clinical experience and that the board has statutory authority to inspect premises and records.

Howard described two categories of required documentation: a biannual inventory (a snapshot of controlled drugs on a specified date that must be maintained at least every two years) and ongoing administration/dispensing logs. He said records must be kept at the DEA-registered location where the drugs are stored (they may not be stored off-site such as at a private residence unless the residence is the registered DEA address). The DEA requires two years of record retention; the board’s medical-record retention standard is three years.

Electronic logging and vendor integration

Howard and Davidson both warned that automated dispensing and logging devices must be configured correctly to produce compliant CURES reports. Howard gave examples where an incorrect schedule or NDC mapping in an electronic system produced inaccurate output; Davidson noted that vendors must format data to the Department of Justice’s specifications or submissions may be rejected. Attendees were advised to confirm with their software or hardware vendors that CURES reporting features are installed and actively submitting data to Bamboo Health.

Practical clarifications offered during Q&A

Speakers answered multiple practical questions from attendees: if a practice stops dispensing controlled drugs (for example, ceases in-clinic dispensing and instead writes prescriptions to outside pharmacies), dispensations are reported by the pharmacy and the practice may not need to submit dispenser reports for those prescriptions; relief veterinarians working under a practice’s DEA registration dispense and report under the practice’s DEA number unless they use their own DEA to prescribe to external pharmacies; expired or unwanted stock is typically removed through reverse distribution services and should be segregated and inventoried until properly destroyed; and controlled-substance access permissions within automated cabinets must be limited to appropriately authorized staff (licensees or DEA-authorized controlled-substance holders).

Ending

The webinar presenters directed practitioners to the CURES helpdesk (cures@doj.ca.gov), the Veterinary Medical Board email (vmb@dca.ca.gov) for follow-up questions, and to posted materials on the board’s website. Davidson and Howard encouraged practices to confirm reporting flows with software vendors, to maintain biannual inventories and dispensing logs at the registered location, and to be prepared to show documentation of CURES submissions during inspections.