Answer: The DEA Controlled Substance Ordering System (CSOS) enables the secure electronic transmission of orders for controlled substances without the A 222 order form. Any registrant authorised to order List II controlled substances may do so electronically via CSOS. The use of electronic controls is optional; Registrants can continue to place orders on a paper-based DEA 222 order form if they prefer. The adoption of CSOS standards is the only authorization for the electronic transmission of orders for List II controlled substances between manufacturers of controlled substances, distributors, pharmacies and other bodies authorized by the DEA. CSOS uses PKI (Public Key Infrastructure) technology where CSOS users must obtain a digital CSOS certificate for electronic control. Electronic orders must be signed with a digital signature issued by the Certification Body (CA) managed by the DEA. 21 CFR 1305.21 (a). Digital certificates can only be obtained by the person who signed the last DEA registration or renewal application, a person authorized to sign an application for registration, or a person who has given a mandate to sign orders by a DEA registrant. 21 CFR 1311.10 (a) &b). A registrant shall designate a CSOS Coordinator who will be the recognized representative of that registrant with respect to matters relating to the issuance, revocation and amendment of digital certificates issued under that registrant`s DEA 21 CFR 1311.20 (a) registration. A CSOS digital certificate is valid until the expiration of the DEA record under which it was issued or until the CSOS CERTIFICATION BODY is notified that the certificate must be revoked 21 CFR 1311.30 (e), 1311.40 (a). Certificates are revoked when the certificate holder is no longer authorized to sign Schedule II orders for the registrant, if the information on which the certificate is based changes, or if the digital certificate used to sign electronic orders has been compromised, stolen, or lost 21 CFR 1311.30(e), 1311.40(a). Answer: Yes.
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