A History of CSOS
The inception of the Controlled Substances Act (CSA) dates back to the 1970’s, and ever since, the Drug Enforcement Agency (DEA) has continued to regulate the method through which Schedule II controlled substances can be purchased. The information included in the act dictates that for a company to place an order for Schedule II controlled substances with their trading partners, the following criteria must be met:
- They must be registered with the DEA under the Controlled Substances Act
- They must complete and deliver a DEA Form 222 to the supplier prior to the order being processed and shipped
For trading partners supplying C2 products, the following criteria must be met:
- They must be registered with the DEA for CSOS Reporting, in order to submit mandatory reports to the DEA every 48 hours
Historically, the process for completing and submitting a DEA 222 Form has been manual and involves filling out a pre-printed form by hand, and then mailing or couriering the form to the supplier. It is estimated that this process takes between 1-3 days when using a courier, and even longer if the form is being sent via regular mail. The idea is that this process allows the DEA to monitor the movement of C2 products, however the time to process an order and the associated costs are quite excessive.
In the early 2000’s, the DEA approved a method to allow companies to issue Schedule II controlled substance orders electronically without the need to physically mail the 222 Form. This led suppliers to acquire 3rd party software systems for use by their customers that allowed for this process -also known as Controlled Substance Ordering Systems (CSOS).
Due to the security measures enforced by the DEA and CSOS certification, software vendors must be certified by the DEA before they can provide true CSOS functionality.