The Office of the Vice Chancellor for Research and Innovation has established this policy for the University of Illinois Urbana-Champaign’s oversight of activities involving Controlled Substances.
This policy applies to Controlled Substances as defined by the Federal Controlled Substances Act of 1970 and the State of Illinois Controlled Substances Act.
This policy applies to all members of the campus community, including but not limited to university faculty (tenure system, specialized, adjunct, visiting), staff, students, postdoctoral appointees, visiting scholars, and visiting scientists, who are engaged in university-sponsored activities conducted in campus facilities or at off-campus locations irrespective of the risks, project scope, or funding.
Office of the Vice Chancellor for Research and Innovation
Activities conducted at or sponsored by the University of Illinois Urbana-Champaign that involve the use of Controlled Substances must be conducted by individuals who are Registrants, Authorized Agents, or Authorized Users.
All Registrants must obtain a State of Illinois Controlled Substance license and a Federal Drug Enforcement Administration registration; keep their State of Illinois license and DEA registration active, in good standing and up to date, including prior notification (and approval) of changes of address, for the duration of time that Controlled Substances are maintained; and maintain an authorized personnel log of all Authorized Agents and Authorized Users.
All Registrants must register with one or both of the applicable campus programs for Controlled Substance surveillance. Registrants engaged in research or teaching activities with animals registered as Veterinary Teaching Hospital patients must register with the VTH Controlled Substance Surveillance Program. Registrants engaged in any other research or teaching activities must be registered with the Division of Research Safety Controlled Substance Surveillance Program.
All Registrants, Authorized Agents, and Authorized Users must comply with all applicable federal and state laws and regulations and university policies, procedures, and guidance related to Controlled Substances.
Failure to comply with this policy may be grounds for discipline by the university, suspension or termination of research or employment, referral for non-compliance/misconduct proceedings, and/or reporting to external licensing or public safety authorities by the university. In addition, failure to comply with state of Illinois and federal Controlled Substances regulations may lead to administrative penalties, civil fines, revocation of State of Illinois Controlled Substance license and/or DEA registration, as well as criminal prosecution.
Activities include manufacturing, administering, dispensing, importing, exporting, conducting research, teaching with and performing chemical analysis with a Controlled Substance.
Controlled Substance is a drug or other substance as defined by state and federal law (the State of Illinois Controlled Substances Act and Title 21 US Code, Controlled Substances Act).
Division of Research Safety is a unit of the Office of the Vice Chancellor for Research and Innovation.
Division of Research Safety Controlled Substance Surveillance Program is a compliance program managed by DRS.
Division of Research Safety Controlled Substance Surveillance Program Manager is the DRS employee who is responsible for implementing the DRS Controlled Substance Surveillance Program.
Veterinary Teaching Hospital Controlled Substance Surveillance Program is a compliance program managed by the Veterinary Teaching Hospital in the College of Veterinary Medicine.
Registrant: A University employee who is registered with the DEA and holds a state of Illinois Controlled Substance license. This registration and licensing process includes a rigorous screening procedure that satisfies university background check requirements for a security-sensitive position. Registrants may supervise specific people who are designated as either Authorized Agents or Authorized Users. The Registrant is ultimately responsible for all activities that fall under the terms of their license and registration.
Authorized Agent: An individual affiliated with the university who has access to the secured location in addition to the ability to handle the Controlled Substance. This individual has the complete trust of the Registrant and is authorized by the Registrant to oversee dispensing and control of the Controlled Substances in the absence of the Registrant. The role of Authorized Agent is a security-sensitive position.
Authorized User: An individual affiliated with the university who may handle Controlled Substances under a Registrant’s license but does not have physical access to the secured location containing the bulk quantities of Controlled Substances. A Registrant or Authorized Agent dispenses limited quantities of Controlled Substances to the Authorized Users for immediate use.
The OVCRI’s Division of Research Safety hosts the Controlled Substance Surveillance Program. This program provides detailed guidance and training on the management of Controlled Substances, including instructions on how to register with the program and how to report suspected diversions.
The Veterinary Teaching Hospital in the College of Veterinary Medicine manages its own medication dispensary and hosts related policy and procedural guidance on its website.
The VTH Controlled Substance Surveillance Program coordinates with the DRS Controlled Substance Surveillance Program on oversight of Registrants who are registered with both programs.
The McKinley Health Center manages its own pharmacy and is separate from the DRS and VTH programs.
The role of Authorized Agent is considered a security-sensitive position that is subject to background checks per CAM Policy HR-47, “Non-Academic Background Investigation Program” and as described in the IHR Service Center, University of Illinois Urbana-Champaign Implementation Guidelines for University of Illinois System Background Check Policy and University of Illinois Background Check Policy – Frequently-Asked Questions – Unit/Department.
There are no exceptions to this policy.
Office of the Vice Chancellor for Research and Innovation
Division of Research Safety
drs@illinois.edu