Five questions from the DocTayo newsletter for 10 November 2026. The correct answer is marked, and every one carries the statute or rule it rests on — so you can check any of them rather than taking my word for it.

Question 1Which controlled substances may be distributed to a pharmacy only against a DEA Form 222 or its electronic equivalent?

The order form requirement reaches Schedule I and Schedule II — the subpart is titled “Orders for Schedule I and II Controlled Substances.” In a community pharmacy you only ever meet the Schedule II half, which is why “Schedule II only” feels right and is wrong. Schedule III through V move on ordinary invoices. CSOS is the electronic equivalent of the form, not an exception to it. Two of the listed exceptions matter to pharmacies: central fill to retail pharmacy, and deliveries made to a registrant by an ultimate user, an LTCF on a resident's behalf, or a person disposing of a decedent's property.

21 C.F.R. § 1305.03

Answering from what a retail pharmacy actually orders rather than from what the regulation covers.

Question 2A DEA Form 222 is completed with an error in the quantity. What happens to it?

A form showing any alteration, erasure or change of any description will not be accepted. The regulation's words are “A defective DEA Form 222 may not be corrected; it must be replaced by a new DEA Form 222 for the order to be filled,” and the original is retained in the files of the purchaser. Keeping it is what makes the sequence of forms account for itself at audit. A note on vocabulary the exam can exploit: this form is defective or unaccepted. Voiding is a different mechanism altogether, done by the supplier when cancelling part or all of an order.

21 C.F.R. § 1305.15(a)(2) and (d)

Correcting and initialing — right on nearly every other pharmacy document, wrong on this one.

Question 3Who must execute a power of attorney authorizing someone to sign DEA Form 222 for a pharmacy?

Three signatures, not one: the registrant (or a partner, or an officer of the corporation), the person to whom the power is being granted, and two witnesses. Revocation is not the same cast: § 1305.05(e) takes the registrant (or partner, or officer) and two witnesses only — the attorney-in-fact is given written notice, not asked to sign. Option B is the interesting wrong answer — it was the actual rule until 30 October 2019, and the last traces of that wording were only deleted from the regulation on 20 March 2026. Older references, including DEA's own 2022 Pharmacist's Manual, still carry it. Neither a pharmacist license nor the pharmacist-in-charge title confers signing authority: a PIC who signs without a power of attorney on file is signing without authority. Since 2019 the power of attorney may be signed electronically by any or all of the required signatories.

21 C.F.R. § 1305.05(d)(1)–(3), (e), (f)

This is one of the places where a 2022-or-earlier source is now simply out of date. If your study guide says “the person who signed the most recent application,” it is quoting a repealed rule.

Question 4A pharmacy destroys expired controlled substances on site. Which form records it, and what happens to the form?

Form 41 is the Registrant Record of Controlled Substances Destroyed, and it must include the names and signatures of the two employees who witnessed the destruction. DEA's own instructions are explicit that you do not submit it unless asked: it is kept as a record of destruction and made available for at least two years. Plenty of pharmacists still believe it gets mailed in; it has not since the 2014 disposal rule. Keep the other numbers apart: 106 is theft or significant loss, 222 is the order form, 224 is the registration application for the dispensing class — practitioners, hospitals and clinics, retail, online and central fill pharmacies, and teaching institutions.

21 C.F.R. § 1304.21(e) (the record); 21 C.F.R. part 1317 (destruction standards and witnessing)

Two traps in one question: believing Form 41 is filed with DEA, and placing the recordkeeping requirement in part 1317. Part 1317 supplies the method; § 1304.21(e) supplies the record.

Question 5A chain opens a second pharmacy across town. What does federal law require of its registration?

Registration follows the address. A separate registration is required for each principal place of business or professional practice at one general physical location where controlled substances are manufactured, distributed, imported, exported or dispensed. Common ownership, a shared state license and physical proximity change nothing: a location dispensing on another location's registration is dispensing without registration. The exemptions are narrow and worth knowing — a warehouse used only for storage (unless it distributes onward), a sales office holding no stock, and a practitioner's prescribing-only office in the same state where nothing is kept, administered or dispensed.

21 C.F.R. § 1301.12(a), with exemptions at (b)

Letting corporate structure stand in for registration. DEA registers physical locations, not companies.

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Written and verified by Adetayo Ogunsanya, PharmD