Controlled Substance Inventory Audits

Controlled Substance Inventory Audits:

Healthcare Consultants has performed hundreds of controlled substance inventory audits on behalf of Pharmacies nationwide. It is important to have an experienced third party conduct these to deal with situations where the DEA and/or Police are involved and your practice and reputation are at stake. Here is an overview of a recent controlled substance inventory audit that we performed for a client:

HCC was contacted by the pharmacy owner regarding the discovery of missing controlled substances. He had initially contacted the Police Department and the Drug Enforcement Administration to report the missing controlled substances. HCC conducted a controlled substance inventory audit on his behalf. Every controlled substance medication in the pharmacy was counted and recorded on a new perpetual inventory log and dated as of the beginning of business. There was a significant number of missing controlled substances according to the records being maintained in the perpetual inventory logs. A DEA Form 106 was then filed detailing the results of the audit up to that point in time.

Then HCC conducted a review of the pharmacy’s invoices showing what had been ordered and what had been logged into the perpetual inventory. Discrepancies showing differences between what was ordered and received and what was logged into the inventory by the Prescription Department Manager were discovered and documented additional controlled substances were documented as unaccounted for). A supplemental DEA Form 106 was filed on behalf of the client to document the additional discrepancy.

HCC then reviewed the results of the inventory audit with the Pharmacist and the Pharmacy owner. New policies and procedures are being implemented to mandate random drug screening of all employees and of any new applicants. Additionally, an independent pharmacy consultant will conduct both regulatory and inventory audits on a biennial basis. The security camera in the pharmacy also had failed and was replaced and located where it could not be tampered with.

HCC also performed a thorough review of the laws and rules regarding inventory requirements listed in CFR 1304.11 (properly executing, filling out and preserving DEA 222 forms as required in CFR 1305.12, CFR1305.13 and CFR 1305.17) with the Pharmacist and the Pharmacy owner. HCC also prepared policies and procedures pertaining to the laws and rules regarding the Issuing of prescriptions (1306.04 & 1306.05), the requirements of what must be on a controlled substance prescription (1306.11), refilling of controlled substance prescriptions (1306.12), the ability to partially fill a prescription (1306.13) and the labelling requirements of a controlled substance prescription (1306.14).

In summary, HCC found that the Pharmacist and Prescription Department Manager did not accurately maintain the proper controlled substance inventory and records surrounding the purchasing, dispensing and documenting of all controlled substances that came into the Pharmacy and this left them open to the possibility of violations and potential liability.

Don’t let this happen to you! Get your policies and procedures regarding Controlled Substance dispensing and record keeping in order now. Plus we recommend that you have an independent third party perform a Controlled Substance Inventory Audit on your behalf before a crisis mandates one being performed.

Healthcare Consulting is a full service Pharmacy Consulting firm that has been in business for over 25 years. HCC has been helping pharmacies plan, prepare and deal with critical business issues such as DEA audits and development of policies and procedures since 1989.

Although we all hope that you will never personally deal with situations such as our client did, be prepared! HCC’s motto has always been that the old cliche “an ounce of prevention is worth a pound of cure” especially applies to running a Pharmacy business. Contact us on line or call us today for a Free Consultation at 800-642-1652 to discuss how we can help you.

Bob Miller
6/7/2015


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