DEA Form 222 & Ordering Schedule II Drugs in a Veterinary Practice (2026)

Ordering Schedule II drugs is not like reordering vaccines or suture. Schedule II — the class that includes many of the drugs a veterinary practice relies on for surgery and euthanasia — has its own ordering system, its own form, and its own paper trail. Getting it wrong doesn’t just delay a shipment; it leaves a gap an investigator will find.

This guide covers how a veterinary practice lawfully orders Schedule II controlled substances: the DEA Form 222, the electronic alternative (CSOS), who is allowed to order, and what you have to record when the shipment arrives.

Why Schedule II is different

Controlled substances in Schedule II carry the highest accountability of the drugs a practice can stock. Because the diversion risk is highest, the DEA controls the ordering channel itself. You cannot simply place a Schedule II order on a distributor’s normal account the way you would for a Schedule IV drug — the order has to move through a DEA Form 222 or its electronic equivalent.

For Schedule III–V drugs, ordering is less restrictive: no Form 222 is required, but you still keep the invoices and record what arrives. This guide focuses on the Schedule II process, which is where practices most often stumble.

The DEA Form 222

The DEA Form 222 is the order form for Schedule II (and Schedule I) controlled substances. It is the document that authorizes a supplier to ship a Schedule II drug to your registered location.

Key things to understand about the current form:

The DEA moved to a single-sheet Form 222 (replacing the old triplicate carbon form). Practices that still have unused legacy forms should confirm current requirements with their supplier and the DEA.
The form is tied to your DEA registration and your registered address — Schedule II drugs can only be shipped to the location on the registration.
The form must be completed accurately and legibly — errors can void it, and a voided form still has to be retained.
You keep your copy of every executed Form 222 with your controlled-substance records.

Because the form is a controlled document in its own right, treat blank 222s like the drugs they order: store them securely and limit who can access them.

CSOS: ordering Schedule II electronically

The Controlled Substance Ordering System (CSOS) is the DEA’s electronic alternative to the paper Form 222. With a CSOS digital certificate, an authorized person can place Schedule II orders electronically — faster ordering, fewer transcription errors, and an electronic record instead of a paper one.

CSOS requires the individual to obtain a personal DEA-issued digital certificate. Many larger or higher-volume practices move to CSOS to speed up Schedule II ordering; smaller practices often stay on the paper Form 222. Either is lawful — what matters is that the channel is one of the two approved ones and the records are kept.

Free download: Ordering is only one of the categories an investigator reviews. Our DEA Self-Audit Checklist walks through all of them — ordering, storage, records, inventory, disposal, and loss reporting — as a self-scoring worksheet. Get the free Self-Audit Checklist →

Power of attorney: who is allowed to order

The DEA registration belongs to the registrant. Only the registrant, or a person the registrant has authorized through a power of attorney, may execute a Form 222 or hold a CSOS certificate to order Schedule II drugs.

A power of attorney for Form 222 authorizes a named individual to sign orders on the registrant’s behalf.
The power of attorney is a written, signed document you keep on file.
It should be kept current — revoked when the authorized person leaves, and reissued for new staff who take over ordering.

During an inspection, an investigator may ask who ordered your Schedule II drugs and to see the power of attorney backing that authority. A missing or outdated power of attorney is a common, avoidable finding.

Receiving a Schedule II shipment

Ordering is only half of it. What you do when the box arrives is just as important, because that is where the drug enters your accountability chain.

When a Schedule II shipment arrives:

Verify the shipment against the order — confirm the drug, strength, and quantity match what you ordered on the Form 222 or through CSOS.
Record the receipt on your executed Form 222 — the form is used to record what was actually received against what was ordered, including the date.
Enter the drugs into your controlled-substance log/inventory the same day — the running balance should reflect the new stock immediately, not “when someone gets to it.”
File the invoice and paperwork with your controlled-substance records.
Secure the drugs in your controlled-substance safe or cabinet before they sit unattended anywhere.

The moment of receiving is a frequent point of failure: the box arrives, gets set down, and the log entry happens hours or days later — or not at all. Making “verify, record, secure” a single unbroken step closes that gap.

The records to keep — and for how long

For Schedule II ordering and receiving, keep:

Your executed Form 222s (or CSOS electronic order records)
Any voided or unusable Form 222s — these are retained, not discarded
The power of attorney authorizing each person who orders
Invoices and packing documentation for every controlled-substance purchase
The log/inventory entries showing the drugs entering stock

Keep these with your controlled-substance records for at least two years, and longer where your state requires it. Schedule II records must be kept separate from other records — one of the details investigators specifically look for.

Frequently asked questions

Do I need a DEA Form 222 for every controlled substance? No — only for Schedule II (and Schedule I). Schedule III–V drugs can be ordered without a Form 222, though you still keep the invoices and record what arrives.

What is the difference between Form 222 and CSOS? Form 222 is the paper order form for Schedule II drugs. CSOS is the DEA’s electronic ordering system that does the same job digitally, using a personal DEA-issued digital certificate. Both are lawful.

Who can sign a DEA Form 222? The registrant, or a person the registrant has authorized through a written power of attorney. Keep that power of attorney on file and current.

Where can Schedule II drugs be shipped? Only to the registered location on the DEA registration used to order them. Each separate location that stocks controlled substances needs its own registration.

How long do I keep Form 222 records? At least two years, kept separate from other records, and longer where your state requires it. Voided forms are retained too.

Turn ordering into a controlled, documented step {#lead-magnet}

Most Schedule II ordering problems come down to two things: an out-of-date power of attorney, and a receiving step where the log entry lags behind the delivery. Both are fixed by a written procedure that everyone follows the same way.

Run the free DEA Self-Audit Checklist to see whether your ordering, receiving, and records would hold up to a visit. And when it shows gaps, the Vet Compliance HQ DEA Controlled Substance Compliance System gives you the ordering and receiving SOPs, a power-of-attorney template, and the logs that keep every Schedule II order accounted for from the form to the shelf.

Get the free DEA Self-Audit Checklist →

Vet Compliance HQ provides educational compliance resources for veterinary practices. This article is not legal advice. DEA and state requirements change and vary by state — verify current requirements with the DEA and your state veterinary board.