The Controlled Substances Ordering System (CSOS) is an electronic commerce initiative overseen by the U.S. Drug Enforcement Administration (DEA) that provides an automated alternative to the current paper-intensive process required for the purchase and distribution of Level I and II controlled substances.
In the current paper-based process, paper forms must be created or updated at every registered shipping location when controlled drugs are transferred. With CSOS, the DEA is defining a system based on digital signatures which allows for the paper forms, known as Form 222, to be replaced by digital messages often referred to as e222 or electronic 222 forms. Purchasers and suppliers may now use either of these methods, paper-based or electronic forms, to fulfill DEA requirements that prevent illegal diversion of controlled drugs.
The DEA proposed rule for CSOS includes technical and business requirements for products used to digitally sign, transmit or receive e222 forms. Software companies that provide these products must participate in an initial audit of the product and additional audits when changes are made to the core digital signing technology. End user companies that build in-house CSOS systems for digital signing, transmission or receipt of e222 forms also must be audited.