- Owner
- Pharmacist in Charge
- Effective date
- September 15, 2026
- Review cycle
- Every 6 months
1.Purpose
To handle controlled substances so that receipt, storage, dispensing and destruction are documented, balances are reconciled, and any loss or discrepancy is caught and reported quickly.
2.Scope
Applies to all scheduled controlled substances received, stored, dispensed and returned by the pharmacy. Follow your local law and the pharmacist in charge's policy for exact recordkeeping requirements.
Definitions
- Perpetual inventory
- A running, transaction-by-transaction balance of a controlled substance maintained alongside the physical stock.
- Two-person verification
- A check where a second authorized staff member independently confirms a count or transaction before it is finalized.
- Diversion
- The unauthorized removal or misuse of a controlled substance from legitimate pharmacy channels.
3.Responsibilities
- Pharmacist
- Performs final checks on controlled substance dispensing and daily balance reconciliation.
- Pharmacy Technician
- Assists with receiving counts, shelving and pulling stock under pharmacist oversight.
- Pharmacist in Charge
- Approves vault access, investigates discrepancies and reports losses as required by law.
- Delivery Driver
- Delivers wholesaler shipments and obtains signature confirmation for controlled substance deliveries.
RACI matrix
| Activity | Pharmacist | Pharmacy Technician | Pharmacist in Charge | Delivery Driver |
|---|---|---|---|---|
| Receive and count controlled substance shipment | A | R | I | C |
| Dispense a controlled substance prescription | R/A | C | I | - |
| Reconcile daily perpetual inventory | R/A | C | I | - |
| Investigate and report a discrepancy | R | I | A | - |
| Approve vault or safe access | C | I | A | - |
R = Responsible, A = Accountable, C = Consulted, I = Informed
4.Materials and PPE
Materials, tools and systems
- โLocked vault or safe rated for controlled substance storage
- โPerpetual inventory log or software module
- โOfficial controlled substance order forms
- โTwo-person count verification sheet
- โDiscrepancy and loss report forms
Personal protective equipment
- โDisposable nitrile gloves
5.Procedure
- 5.1
Verify the shipment against the order
PharmacistOn delivery, compare the wholesaler's shipment to the original order form and packing slip, checking drug names, strengths and quantities before signing for receipt.
- 5.2
Perform a two-person receiving count
Pharmacy TechnicianCount each controlled substance item with a second authorized staff member present, and have both people sign the receiving count verification sheet.
Checkpoint: The receiving count is signed by two authorized staff members before stock is shelved.
- 5.3
Log the shipment into the perpetual inventory
PharmacistEnter the received quantity into the perpetual inventory log or software immediately after the count, updating the running balance for each item.
- 5.4
Store in the vault or safe
Pharmacy TechnicianPlace controlled substances in the locked vault or safe designated for that schedule, restricting the combination or key to authorized staff only.
- 5.5
Verify the prescription before dispensing
PharmacistCheck the prescription for validity, prescriber authority and any red flags for diversion, such as early refill requests or unusual quantities, before filling.
Warning: Do not dispense a controlled substance prescription that raises unresolved diversion concerns without further verification.
- 5.6
Dispense with technician assistance
Pharmacy TechnicianHave the technician pull and count the medication under direct pharmacist oversight, then hand off for the pharmacist's final check.
- 5.7
Record the dispensing transaction
PharmacistLog the dispensed quantity in the perpetual inventory immediately, updating the running balance for that item and patient.
- 5.8
Reconcile the daily balance
PharmacistAt the end of each day, compare the physical count in the vault or safe against the perpetual inventory balance for each controlled substance.
Checkpoint: The physical count matches the perpetual inventory balance before the reconciliation is signed off.
- 5.9
Investigate any discrepancy immediately
PharmacistIf the physical count does not match the perpetual inventory, recount immediately, review recent transactions, and document the investigation the same day.
- 5.10
Report loss or theft
Pharmacist in ChargeReport any confirmed loss, theft or unresolved discrepancy to the pharmacist in charge and to the appropriate authorities as required by local law.
- 5.11
Return expired or unused stock
PharmacistSegregate expired or unused controlled substances for return through an authorized reverse distributor, following the expired medication disposal SOP for documentation.
- 5.12
Review vault access periodically
Pharmacist in ChargeReview the list of staff with vault or safe access on a set schedule, removing access for anyone who has changed roles or left the pharmacy.
6.Quality checks
- โEvery receipt is counted and signed by two authorized staff.
- โThe perpetual inventory balance matches the physical count at each daily reconciliation.
- โEvery dispensing transaction is logged the same day it occurs.
- โVault access is limited to staff on the current authorized list.
7.Records
- โPerpetual inventory log
- โTwo-person receiving count sheets
- โDaily reconciliation records
- โDiscrepancy and loss reports
8.KPIs
- โNumber of unresolved discrepancies per month
- โPercentage of daily reconciliations completed on time
- โAverage time to resolve a flagged discrepancy
- โNumber of vault access changes reviewed per quarter
9.Common mistakes
- โShelving a controlled substance delivery before completing the two-person count.
- โDelaying the perpetual inventory entry until later in the shift.
- โSkipping the daily reconciliation on a busy day.
- โLeaving vault access unreviewed after staff turnover.
10.Revision history
| Revision | Date | Description | Reviewed by |
|---|---|---|---|
| 1.0 | September 15, 2026 | Initial release | Ilia Pirozhenko |
This is a template. Adapt it to your organization, equipment and local regulations before use.