Important Information on Issues Related to Controlled Substances
Annual Controlled Substance Inventory
Registration Requirements for the Use of Controlled Substances
Destruction of a Controlled Substance
Licensees must maintain an inventory of all controlled substances under their control and submit an annual inventory of these substances to the state between April 1 and June 30. An inventory is required for each location where controlled substances are kept, beginning on the day the licensee first engages in the practice. The inventory shall be signed and dated (including whether it is the opening or closing of the day), and include the licensee's name, address and DEA number.
Schedule 2 drugs should be listed separately from all other drugs and exact counts should be made. For substances listed in schedules 3, 4 and 5, the count or measure may be estimated, but if the container holds more than 1000 dosage units (pills, etc.), then an accurate count is required. Federal law requires a biannual inventory be taken and kept on the premises. Saving a copy of the annual state inventory will put the veterinarian in compliance with this requirement. Send the state inventory to:
State of Michigan
Bureau of Health Professions
Health and Regulatory Division
6546 Mercantile Way, Suite 2
PO Box 30454
Lansing, MI 48909
For questions call 517/373-1737 or email email@example.com.
The use of controlled substances is regulated by both the Michigan Public Health Code and the U.S. Code of Federal Regulations (CFR) and their applicable rules. The following is a summary of the licensing and registration requirements, as they apply to veterinarians practicing in Michigan. It by no means covers all the regulations and their variations. When in doubt, contact the Federal Drug Enforcement Administration (DEA) or the Michigan Bureau of Health Professions.
Michigan Controlled Substance License (MCSL)
To legally "prescribe" a controlled substance, a veterinarian must have a valid Michigan controlled substance license. Prescribe means to make the medical decision (order) to use a controlled substance by administration, dispensing, or written prescription.
Every veterinary practice location that stocks controlled substances on the premises must have a separate DEA registration for the veterinarian who obtains the controlled substances for that location.
To issue a written prescription for a controlled substance, the CFR requires that a veterinarian have his/her own DEA registration, however, the registration does not have to be specific for the location.
Section 1301.22 of the CFR allows a practitioner, who is an agent or employee of the DEA registered veterinarian for that location, to administer and dispense controlled substances in the normal course of his/her employment under the registration of the employer in lieu of being registered him/herself. However, the Michigan Automated Prescription System (MAPS) monthly report for controlled substances dispensed requires that the dispensing veterinarian’s name and DEA number be listed on the report.
The veterinarian whose DEA number is used to obtain the controlled substances for the location is ultimately responsible for tracking the use of the controlled substances, including filing the Michigan Annual Inventory for that location.
Veterinary Practices with More Than One Facility/Location
Each practice facility (location) that stocks controlled substances must have a veterinarian registered with the DEA from that specific location and separate from registrations from other locations. That veterinarian is responsible for the controlled substances for that location.
The specific location from which a controlled substance is dispensed is not required for MAPS reporting, therefore the MAPS report may be made from a central location of a practice with more than one facility location. The name and DEA number of the dispensing veterinarian must be listed on the report. The location from which the controlled substance was dispensed should be documented by the practice.
A practice with more than one facility location will probably want to order controlled substances separately for each location, as transferring controlled substances from one location is complicated. Each location where controlled substances are kept must file a Michigan Annual Inventory.
Who needs a Michigan Controlled substance license?
Any veterinarian who uses/prescribes a controlled substance.
Who needs a DEA registration number?
Any veterinarian that dispenses (MAPS requirement) or issues a written prescription for a controlled substance. Any veterinarian who obtains/purchases a controlled substance. That registration must be specific for the location.
Who does not require a DEA registration to use a controlled substance?
A veterinarian who administers a controlled substance as the agent or employee of another veterinarian who posses the controlled substance. A non-veterinarian (assistants/technicians) acting under the orders and supervision of an appropriately licensed/registered veterinarian.
The MVMA thanks Mr. Michael Wissel at the Michigan Bureau of Health Professions for his assistance for preparing the information above.
Methods of Destruction
In compliance with the State of Michigan Department of Environmental Quality, the following methods of destruction for controlled substances are recommended:
Make arrangements with a DEA Reverse Distributor.
Make arrangements with a DEA approved Registrant for the use of their incinerator (Medical/Veterinary facilities).
Make arrangements with a State approved Waste/Treatment facility.
Destroy onsite by dissolving tablets in water or non-toxic fluids, then pour dissolved mixtures, and all other fluids into kitty litter, allow to harden, and then discard.
IMPORTANT NOTICE: Only those persons registered with and authorized by DEA to handle controlled substances may utilize/submit this information.
Reports Required by 21 CFR
Access DEA 21 CFR Forms Here
Destruction of Controlled Substances
Import/Export Declarations (Chemical Reports)
Import/Export Permit Applications and Declarations (Controlled Substances)
Quota Applications and Year-End Reports
Theft or Loss of Controlled Substances