The DEA expects tight control over the inventory of controlled substances and thefts/losses have to be reported immediately. This opens a minefield of regulation that is best left to the experts. Controlled substances are the prime targets for theft and diversion. It could be due to lax security or even a long-time employee or relative may be perpetrating the act. Whatever be the reason, any kind of irregularity, diversion or theft of DEA scheduled drugs has to be reported immediately. The Drug Enforcement Administration (DEA) expressly requires that any theft or significant loss of controlled substances should be reported in writing to the area DEA field office on DEA Form 106 either electronically or manually within one business day of the discovery. However, minor discrepancies in inventory that are not attributable to theft do not have to be reported or recorded on a DEA Form 106. This may sound simple at first. However, there are complications at every step - from what constitutes a significant loss to the ‘upon discovery’ rule. Quantifying of a significant loss will obviously vary based on the level of business activity and environment. What is significant for a small corner drugstore is minor for a large healthcare system…. Federal regulations provide the following factors to be considered for determining whether the loss of a controlled substance is significant or not:
However, this is not exclusive and other factors can also come into play in some cases. For instance, the DEA itself warrants that, “the repeated loss of small quantities of controlled substances over a period of time may indicate a significant aggregate problem triggering reporting even where the quantity lost in each occurrence, by itself, is not significant.” Again, the short reporting window of one business day from discovery can prove to be exceptionally taxing, especially when it is difficult to determine whether it is a theft or loss. While it is always better to err on the side of caution and alert the authorities in a timely manner, this will be followed by providing the DEA with updates for up to two months about the possible causes or source. And everything has to be in writing and submitted either electronically or manually. Therefore, it is better to leave the headache of reporting the DEA Form 106 to qualified experts like the Titan Group https://titangroupdea.com
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