11.2 Controlled Substance Inventories & Utah's Schedule II Perpetual Inventory
Key Takeaways
Utah requires a controlled substance inventory within 12 months after each inventory date, which may be taken within four days of the specified date (R156-17b-605(4)).
A Utah inventory must include out-of-date drugs and drugs in automated pharmacy systems, and may be taken at the opening or close of business on the inventory date (R156-17b-605(2)).
Schedule I and II drugs require an exact count; Schedule III–V may be estimated unless the container holds more than 1,000 tablets or capsules, in which case an exact count is required.
The PIC must sign and date each initial, annual, change-of-ownership, and closing inventory within 72 hours or three working days, and inventories are kept five years, filed separately.
Every Utah pharmacy must keep a perpetual inventory of Schedule II controlled substances and reconcile it according to facility policy (R156-17b-605(6)).
11.2 Controlled Substance Inventories & Utah's Schedule II Perpetual Inventory
Blueprint item 4.2 includes "requirements for conducting controlled substance inventories." Utah's rule, R156-17b-605, is stricter than federal law in frequency and adds a perpetual inventory requirement.
Federal baseline vs. Utah
| Feature | Federal (21 CFR 1304.11) | Utah (R156-17b-605) |
|---|---|---|
| Initial inventory | When first engaging in business | On the opening day of business, including out-of-date drugs and drugs in automated systems. If there is no Schedule I or II stock, record that fact separately from the Schedule III–V record. |
| Periodic inventory | At least every two years (biennial) | Annual: within 12 months following the inventory date each year, and it may be taken within four days of the specified date |
| Change of ownership | Inventory at transfer (21 CFR 1301.52) | Inventory of legend drugs and controlled substances on the date of the qualifying ownership change. It is the seller's closing inventory and the buyer's initial inventory, and any Schedule I or II transfer uses DEA Form 222. |
| Closing | Per DEA discontinuance rules | A closing inventory, attested in the surrender notice to DOPL (R156-17b-604(5)) |
| Combining two pharmacies | — | A separate closing inventory for each pharmacy, then a combined opening inventory for the new pharmacy |
| Perpetual inventory | Not required | Required for Schedule II, reconciled according to facility policy |
| Retention | 2 years | 5 years, filed separately from other records |
How to take the inventory (R156-17b-605(2))
- Who: the PIC (or consulting pharmacist, RDPIC, or DMPIC) is responsible, but may delegate the counting.
- When: at the opening or close of business on the inventory date. The person taking it and the PIC must state the time, and sign and date it with the date it was taken. The PIC's signature and date must be documented within 72 hours or three working days of an initial, annual, change-of-ownership, or closing inventory.
- Form: written, typewritten, or printed. An inventory recorded by voice must be promptly transcribed.
- Scope: every stock of controlled substances on hand on the inventory date, including out-of-date drugs and drugs in automated pharmacy systems.
- Separation: list Schedule I and II separately from Schedules III–V, and file inventories separately from other records.
- Perpetual reconciliation: if a perpetual inventory is kept for any drug being inventoried, reconcile it on the inventory date.
Counting rules
| Schedule | Counting method |
|---|---|
| I and II | Exact count or measure |
| III, IV, V | Estimated count or measure permitted, but if the container holds more than 1,000 tablets or capsules, make an exact count |
The federal rule is similar: exact counts for Schedule I and II, and estimated counts for opened Schedule III–V containers unless the container originally held more than 1,000 units. Federal inventories also record the registrant's name, address, and DEA number, the date and whether the count was at opening or close, and for each item the name, strength, dosage form, units per container, and number of containers.
The Schedule II perpetual inventory (R156-17b-605(6))
"A pharmacy shall maintain a perpetual inventory of Schedule II controlled substances that shall be reconciled according to facility policy." Utah requires the perpetual inventory for every pharmacy, not only hospitals or compounding pharmacies, and leaves the reconciliation schedule to the pharmacy's written policy. Good practice is to:
- record each receipt (with the invoice or Form 222 reference), each dispensing (prescription number and quantity), transfer, return, and destruction as it occurs;
- reconcile the book balance against a physical count on a set schedule (for example, weekly or monthly) and at each annual inventory; and
- investigate discrepancies promptly. Unexplained shortages may be a theft or significant loss requiring DEA and DOPL reporting (Section 11.3).
Remote dispensing pharmacies must document monthly inspections that include maintenance of a perpetual inventory of Schedule II drugs and reconciliation of any controlled substances (R156-17b-614g(10)).
When a drug becomes controlled
Federal law requires an inventory of a newly scheduled substance on the effective date of the scheduling (21 CFR 1304.11(d)). Utah's 2024 gabapentin scheduling is the local example. Gabapentin became Utah Schedule V on May 1, 2024, and DOPL directed pharmacies to take an initial gabapentin inventory on or after May 1 but before May 31, 2024, and to include gabapentin in each annual controlled-substance inventory from then on.
Related records
- Receipts: a pharmacist or other responsible person must verify that controlled substances on suppliers' invoices were actually received, by initialing and dating the invoice with the actual receipt date. Keep credit memos for controlled substances (R156-17b-614a(11)–(12)).
- DOPL access: inventory copies must be made available to DOPL on request (R156-17b-614a(13)). Failing to account for shortages, or refusing to make inventory available for inspection, is unprofessional conduct (R156-37-502(5), (7)).
Scenario
A pharmacy's last annual inventory was taken June 10, 2025 at close of business. The next must be taken within 12 months, by about June 10, 2026 (the rule allows four days either way), at opening or close of business. It includes expired stock and automated-cabinet stock, and the PIC signs within 72 hours or three working days. Schedule II items are counted exactly. A 1,000-count bottle of acetaminophen/codeine with about 600 tablets left may be estimated. A 5,000-count bottle of a Schedule IV drug must be counted exactly.
A Utah pharmacy took its last annual controlled substance inventory on June 10, 2025 at close of business. When must it take the next one under R156-17b-605?
Every six months
Only when the PIC changes
Within 12 months following the inventory date (around June 10, 2026, within four days of that date), at the opening or close of business
By June 10, 2027, because the federal biennial rule controls
During the annual inventory, a pharmacist finds an opened 100-count bottle of oxycodone/acetaminophen with 42 tablets, an opened 1,000-count bottle of acetaminophen/codeine #3 with about 600 tablets, and an opened 5,000-count bottle of diazepam. How should each be counted under Utah and federal rules?
Exact counts for all three, because Utah prohibits estimates
Exact counts for the oxycodone/acetaminophen and the diazepam, and an estimated count for the acetaminophen/codeine
Estimated counts for all three, because they are opened containers
An exact count for the diazepam only
Which continuous controlled-substance record does R156-17b-605 require of every Utah pharmacy?
No perpetual inventory is required in Utah
A perpetual inventory of all Schedule II–V controlled substances, reconciled daily
A perpetual inventory of Schedule V drugs only
A perpetual inventory of Schedule II controlled substances, reconciled according to facility policy
Within what time must the PIC sign and date a Utah annual controlled substance inventory after it is completed?
Within 72 hours or three working days
At the next self-audit
No PIC signature is required if a technician did the count
Within 30 days
Sections you finish are checked off in the contents.