6-D-5 Guidance: What’s Changed

Facilities across outpatient and ambulatory settings—including surgery centers, office-based surgery/procedural practices, and pediatric dental practices—should be aware of important updates to the interpretive guidance for QUAD A Standard 6-D-5.

What’s the standard?
6-D-5: If contracted anesthesia professionals bring controlled substances (CS) into the facility, the organization is responsible for ensuring full compliance with all QUAD A standards, as well as applicable local, state/provincial, and federal laws and DEA regulations.

What’s new in the guidance?
The updated interpretive guidance places stronger emphasis on reducing the risk of controlled substance diversion through both contractual oversight and day-to-day operational verification. This means facilities must go beyond having policies and contracts in place—they must actively confirm compliance.

Key areas of focus when evaluating compliance:

• Contract & registration verification
  Ensure a written contract clearly specifies that the facility retains responsibility for anesthesia services, and that the contracted anesthesia organization retains responsibility for the procurement, recordkeeping, and security of controlled substances.
  
• Operational compliance
  Verify that the facility maintains a copy of the contracted anesthesia professional’s controlled substance dispensing log for each day controlled substances are administered onsite.
• On-site storage and security
  Confirm that all controlled substances brought into the facility by the contracted anesthesia organization are stored and secured in compliance with applicable federal, state/provincial, and local regulations.
  

Why this matters

These updates reinforce that compliance is a shared responsibility—but ultimately, the facility is accountable for ensuring systems are in place to prevent diversion, support traceability, and meet regulatory expectations. The updates also clarify that the contracted anesthesia organization is responsible for compliance with DEA registration requirements for each location, if applicable, and with recordkeeping requirements.

Questions 

Thank you for your continued dedication to safety and excellence. If you have any questions or require further clarification, please email standards@quada.org.

Since 1980, QUAD A (a non-profit, physician-founded and led global accreditation organization) has worked with thousands of healthcare facilities to standardize and improve the quality of healthcare they provide – believing that patient safety should always come first.