Controlled-substance inventory for Florida pharmacies

What the DEA and Florida ask of your controlled-substance inventory, and who to tell about a theft or significant loss. Each rule in plain words, with its source.

What the rules ask

Take a full inventory of every controlled substance on hand at least every two years.21 CFR 1304.11(c)
Write on it whether you took it at the opening or the close of business.21 CFR 1304.11(a)
In an opened container, count Schedule II exactly. Schedules III to V may be estimated, unless the container holds more than 1,000 tablets or capsules.21 CFR 1304.11(e)(6)
Keep a current record of what comes in and what goes out. A perpetual inventory is not required.21 CFR 1304.21(a); Florida Statutes s. 893.07(1)(b)

Florida’s own law asks for the same inventory, every second year.

Florida Statutes s. 893.07(1)(a).

Every two years, on the calendar

The DEA’s rule lets the inventory fall on any date within two years of the last one. An inventory taken on March 2, 2026 makes the next one due by March 2, 2028.

Our suggestion, not a rule: count far more often than that, so a difference turns up while there are fewer transactions behind it.

Who keeps the records

Every Florida community pharmacy permit names a prescription department manager (PDM), and the PDM keeps the drug records state and federal law require.

Florida Statutes s. 465.018(2) and s. 465.022(11)(a).

When the pharmacy changes hands

If the person or business that holds the permit changes, the pharmacy needs a new permit. With controlled substances on hand, the new permit records an opening inventory for the DEA.

Florida Administrative Code 64B16-28.2021(1) and (4).

A theft or significant loss

From the day you discover it:

Tell the sheriff of your county within 24 hours.Florida Statutes s. 893.07(5)(b)
Tell your DEA Field Division Office, in writing, within 1 business day.21 CFR 1301.76(b)
The PDM tells the Florida Board of Pharmacy within 1 business day.Florida Statutes s. 465.022(11)(b)
File DEA Form 106 online within 45 days.21 CFR 1301.76(b)

Report a theft, or a loss that is significant. Significant depends on the amount for your pharmacy, which drugs, a link to who had access, a pattern of losses, the chance of diversion, and local trends.

21 CFR 1301.76(b)(1) to (6).

Keep a record of what was lost or stolen: the kind, the quantity and the day you found it.

Florida Statutes s. 893.07(5)(a).

How NarcCount handles Florida

For a Florida pharmacy, NarcCount:

Names each drug from its NDC, with its DEA schedule, from the FDA’s NDC Directory.
Prints the inventory record with your DEA number, Florida permit number and PDM, marked opening or close of business.
Works out what you should have on hand from your purchase, dispensing and destruction records.
Schedules a full count every 1 to 6 months, your choice, and emails a reminder before each one is due.
Lists who to tell about a theft or significant loss, and by when, from the day you find it.

NarcCount assists your inventory and reconciliation; it does not replace your professional obligations.

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This guide is general information, not legal or professional advice. For the authoritative requirements, refer to the DEA and the Florida Board of Pharmacy.

Sources

Show the 7 sources

21 CFR 1304.11 — Inventory requirements (DEA) — Federal (DEA): “the registrant shall take a new inventory of all stocks of controlled substances on hand at least every two years” (c); it “may be taken either as of opening of business or as of the close of business on the inventory date and it shall be indicated on the inventory” (a); in an opened container a dispenser makes an exact count of Schedule II and an estimated count of Schedules III–V, “unless the container holds more than 1,000 tablets or capsules” (e)(6).
21 CFR 1304.21(a) — General requirements for continuing records (DEA) — Federal (DEA): a complete and accurate record of each controlled substance received and disposed of, kept “on a current basis … except that no registrant shall be required to maintain a perpetual inventory”.
21 CFR 1301.76(b) — theft or significant loss (DEA) — Federal (DEA): notify the Field Division Office “in writing, of the theft or significant loss of any controlled substances within one business day of discovery”, and “file a complete and accurate DEA Form 106 … through DEA's Diversion Control Division secure network application within 45 days after discovery”. The same paragraph lists what decides whether a loss is significant, (1)-(6). Amended June 22, 2023 (88 FR 40712).
Florida Statutes s. 893.07 — Records (The 2026 Florida Statutes) — Florida: a complete and accurate record of all controlled substances on hand “every second year”, which may be taken on the regular physical inventory date “which is nearest to, and does not vary by more than 6 months from, the biennial date” (1)(a); “this subsection shall not require the maintenance of a perpetual inventory” (1)(b); a record of controlled substances lost, destroyed or stolen, with the kind, quantity and date of discovery (5)(a); and a theft or significant loss reported “to the sheriff of that county within 24 hours after discovery” (5)(b).
Florida Statutes s. 465.018(2) — Community pharmacies; permits — Florida: “No permit shall be issued unless a licensed pharmacist is designated as the prescription department manager.”
Florida Statutes s. 465.022(11) — the prescription department manager — Florida: the prescription department manager “must obtain and maintain all drug records required by any state or federal law to be obtained by a pharmacy” (a), and “must notify the board of any theft or significant loss of any controlled substances within 1 business day after discovery of the theft or loss” (b).
Florida Administrative Code 64B16-28.2021 — Change of Ownership — Florida: a change in the person or business entity holding the permit needs a new application and a new permit (1), and “if the old permit has controlled substances, the new permit must record an ‘opening inventory’ for DEA purposes” (4).

Primary sources for the figures on this page. Regulations change; confirm the current requirement with the source before you rely on it.