LogButler DEA Compliance Blog
Controlled Substances Logging Mistakes That You Should Avoid
How does your facility treat logging of controlled substances? Does your personnel track the use of every used milliliter, including waste? The thing is many facilities simply lack confidence in their logs, commonly lacking a clear routine and procedures for controlled substances logging. As a result, they face many logging mistakes and often larger compliance issues.
5 Сommon Logging Mistakes that Clinics Shouldn’t Ignore
Logging mistakes are the most common reason why clinics end up with DEA penalties and fines for non-compliance. A single violation may incur over $19,000 and they may shockingly multiply, leading a clinic to unwanted charges and lawsuits.
If violations are numerous or extend beyond recordkeeping mistakes into negligence, practitioners also risk losing their DEA registration and medical license, often permanently.
1. Failing to Make a Record in Real Time
At the federal level, you must record every transaction on a current basis, meaning that you should keep all your logs updated regularly.
“Every registrant required to keep records pursuant to § 1304.03 shall maintain, on a current basis, a complete and accurate record of each substance manufactured, imported, received, sold, delivered, exported, or otherwise disposed of by him/her…”
Honestly, we all know how hard it is to record the exact amount of drugs at the end of each shift. The worst scenario is when logging is postponed until the end of the week. It means you’ll have to recollect and document the exact amount of doses, waste, client name, reason, and many other details.
Paper logbooks make it even harder to catch an error or missing information – issues that will be most likely flagged by a DEA inspector.
On the contrary, digital logbooks allow you to create a log of any controlled substance in your stock in a few seconds and find errors faster.
Logbulter, for example, provides real-time logging that is highly approved by DEA auditors. Our digital logbook helps make real-time logging simple and accessible, while improving your clinic’s compliance.
It is aligned with federal recordkeeping requirements, allowing medical staff to log everything in real time, spot inconsistencies, missing or lost entries, and save more time for their patients.
2. Neglecting Logs Reconciliation on a Daily Basis
The more often you reconcile your logs with PIMS records, invoices, and physical stock numbers, the less likely you are to face discrepancies and compliance issues. Again, if you consult with eCFR, it requires DEA registrants to ensure their records are accurate and up-to-date at all times.
So, how frequently should you reconcile – daily, weekly, or monthly? LogButler recommends reconciling daily since it helps proactively find and resolve possible discrepancies.
Daily reconciliation would simplify physical counts, helping to manage your controlled substances more effectively. Besides, it’s always better to have logs in good shape before any unannounced visit of a DEA inspector.
The LogButler digital logbook makes daily reconciliation of logs almost effortless. You can have a clear picture of all transactions related to a specific controlled drug in just a few clicks.
Sure, if you still rely on a paper-based logbook, daily reconciliation can feel unrealistic, making it easier for discrepancies to slip through.
3. Improperly Correcting and Adding Changes
Never cross-out entries, apply correction fluid, rewrite records or alter records without marking that it’s an error. Any corrections must be done in such a way that the original entry is still noticed.
If on paper, you should place an error in brackets and in the margin or footnote, explain what type of error it is, e.g., calculation mistake. Add the right variant to a new line or a separate page, sign, and write the date of correcting a record.
If you use a digital logbook, everything will be way simpler. It guides you and keeps a clear audit trail with all the necessary details of the change, also maintaining the original entries with timestamps. All the log transactions are tracked, easily accessed, and displayed upon your request.
Find more benefits from transitioning to a digital logbook in our related article.
4. Failing to Address Missing or Lost Records
Any gaps flagged in logs may be considered as recordkeeping violations, especially if you lack supporting documentation like necessary DEA Forms for loss or theft of controlled substances. Which is why it’s critical to timely capture a missing entry or lost record.
You should keep in mind that by the federal law, you must maintain controlled substance records for 2 years at least. Hence, if any record is absent and you can’t locate it after several attempts, you should recognize it asap, investigate the reason, and document the incident. Try to restore the missing data using available invoices, patient charts, inventory counts, dispensing logs, etc. If missing records imply theft or loss of controlled substances, you must report this incident to DEA using Form 106.
The greatest advantage of a digital logbook LogButler is that all your logs are kept in a cloud-based digital system where each entry is timestamped, tamper-proofed, and connected to specific user’s activities. Every log is traceable and safeguarded by permission-based access. Plus, there’s a history of changes and data backup.
5. Not Having an SOP for Logging Controlled Substances
Any clinic that administers controlled substances should have a standard logging routine so that everyone who “touches” a controlled drug is accountable. It is often called Standard Operating Procedures (SOPs) for handling controlled drugs. The DEA doesn’t directly say “rely on SOPs when logging” but still require consistency in recordkeeping.
The main role of SOPs is to establish a clear procedure of dealing with controlled drugs. This way you formalize how and when your staff should log controlled substances when ordering, receiving, dispensing, disposing medications, etc.
By the way, limiting access to controlled drugs with a list of authorized personnel will help you ensure fewer mistakes in your records and prevent diversion. LogButler, for example, establishes granular access to logs through secure PIN codes and digital signatures for staunch security.
To Sum Up
Having well-written SOPs doesn’t guarantee an error-free logging routine. You should also ensure that everyone who has access to controlled drugs always meets your procedures consistently.
With LogButler, you’ll have real-time tracking of your personnel’s logging activities and any attempt to alter logs will be visible and easily tracked to. Plus, SOPs can be integrated into your digital logbook, fully aligned with your clinic’s workflow and needs.
LogButler is a DEA-compliant digital logbook that also comes with customizable modules like PDMP for 1-click reporting.
Let’s talk first to help you understand LogButler’s benefits for your clinic.
