VetOnIt clinical notes
Controlled substance recordkeeping: counts, discrepancies and retention
Practical controlled-substance recordkeeping points from Vet On It's DEA compliance course: why trend-only reconciliation misses diversion, cycle counts, discrepancy handling, written procedures and record retention.
Updated · VetOnIt
Reconciliation that actually catches diversion
Reconciling only by usage trends can let diversion go unnoticed, because early problems are missed while the trend is being established. [1]
There is no single right cycle-count frequency for a drug; it depends on how often the drug is used, so a discrepancy does not leave an unmanageable number of log entries to investigate. [1]
Document every adjustment to a count with the reason for the change. If a discrepancy cannot be resolved, that is when a theft or loss report is needed. [1]
Written procedures and record retention
A practice's written controlled-substance procedures should cover who can order and access controlled substances, record storage, inventory, documentation of dispensing, prescribing and administration, and handling of discrepancies. DEA field agents want to be a resource for practices. [1]
Federally, controlled-substance records must be kept for at least two years; some states require longer, so check state law. [1]
Related lectures
On-demand lecture
Essential Controlled Substances: DEA Compliance, Recordkeeping, and Diversion Prevention in Veterinary Practice
View on-demand lecture →References
- Essential Controlled Substances: DEA Compliance, Recordkeeping, and Diversion Prevention (lecture recording, Apr 7 2026) VetOnIt lecture transcriptLecture source retained by VetOnIt.