DEA Required Inventories:  Initial and Biennial

One of the most common discrepancies DEA registrants should be aware of involves the Initial and Biennial Inventories.  A majority of DEA registrants either maintain incomplete inventories or maintain no inventories at all.  Even if your facility does not maintain controlled substances on site, these inventories must be completed and list zero as the quantity of controlled substances on hand.

Each DEA registrant is required to take an Initial Inventory of all controlled substances on hand on the date they first engage in controlled substances activity.  The DEA requires that the inventory include:

    a.  The inventory date.

    b.  The time the inventory is taken (i.e., opening or close of business).
    c.  The drug name.
    d.  The drug strength.
    e.  The drug form (e.g., tablet, capsule, etc.).
    f.   The number of units/volume.
    g.  The total quantity.

DEA recommends that the inventory record include:

    a.  The name, address and DEA registration number of the registrant.

    b.  The signature of the person or persons responsible for taking the inventory.

Include in your inventory controlled substances that have been supplied to you as samples and controlled substances that have expired and are awaiting destruction.  Controlled substances listed in Schedule II must be recorded separately from those controlled substances listed in Schedules III, IV, and V.  DEA does not provide a specific form for inventories; registrants must record this information on a separate record from all other records of their business.

After the Initial Inventory is conducted, each DEA registrant must inventory all controlled substances on hand at least every two years.  This Biennial Inventory should include the same information as the Initial Inventory and must be continued every two years as long as the DEA registration is active.

Although these inventories are required by DEA, you are not required to send a copy to DEA.  You are only required to keep these inventories on file and available for inspection for at least two years from date of inventory.  Your facility should still conduct daily, weekly and/or monthly inventories to assure accurate and consistent records for your controlled substances.      

If you follow these simple guidelines, your DEA registration will fall into the small percentage of registrants who follow federal requirements, thus, keeping your registration in good standing.