Perpetual Inventory and Monthly Reconciliation Public Act 18-16 Section 5 of Public Act 18-16 added a requirement for a pharmacy and an institutional pharmacy to maintain a perpetual inventory for all Schedule II controlled substances.  In addition, the perpetual inventory must be reconciled on a monthly basis.  Below are some frequently asked questions pertaining to the new law.   Perpetual Inventory

1. What is a perpetual inventory of schedule II controlled substances?
   1. A perpetual inventory is the maintenance of an accurate count of all schedule II controlled substances in a pharmacy or institutional pharmacy.
2. Who is required to keep a perpetual inventory of schedule II controlled substances?
   1. A pharmacy means a place of business where drugs and devices may be sold at retail and for which a pharmacy license has been issued to an applicant under the provisions of section 20-594 licensed in pursuant to Connecticut General Statutes.
   2. An institutional pharmacy means that area within a care-giving institution or within a correctional or juvenile training institution, commonly known as the pharmacy, that is under the direct charge of a pharmacist and in which drugs are store and dispensed (C.G.S. 20-571).
3. Can the perpetual inventory be maintained electronically?
   1. Yes provided it keeps an accurate, real-time count of all schedule II controlled substances in the pharmacy or institutional pharmacy.The pharmacists on duty must be able to access the count of schedule II controlled substances for verification as necessary.
4. Does an automated dispensing machine/cabinet inventory record system comply with the perpetual inventory requirement?
   1. If the automated dispensing machine/cabinet maintains an accurate record of schedule II controlled substances, then it would comply with the perpetual inventory requirement.
5. What records of the perpetual inventory of schedule II controlled substances are required to be maintained?
   1. All schedule II perpetual inventory records are required to be maintained on the premises of the pharmacy or institutional pharmacy in an orderly manner, separate from all other records.  The records shall be filed chronologically by date and retained for not less than three (3) years.  The records shall be made immediately available for inspection and copying by the Commissioner of Consumer Protection, the commissioner’s authorized representatives or other persons authorized to review such records pursuant to section 21a-265 of the general statutes.
6. What should I do if I find a discrepancy in the perpetual inventory?
   1. Any loss, theft or unauthorized destruction of a controlled substance discovered during the reconciliation shall be reported to the Drug Control Division by a pharmacy or institutional pharmacy not later than seventy-two hours after discovery.  The preferred way to report this loss is to DCP.DrugLoss@ct.gov.The Drug Enforcement Administration (DEA) should also be notified on a DEA 106 form.

  Monthly Reconciliation

1. What does it mean that the perpetual inventory of schedule II controlled substance must be reconciled monthly?
   1. At least once each month, the pharmacy or institutional pharmacy shall compare the perpetual inventory against the actual, on-hand inventory of schedule II controlled substances.
2. Can a cycle count be used to satisfy the monthly reconciliation requirement?
   1. If the cycle count is done once each month and comparison of the perpetual inventory against the actual inventory occurs, then it can be used to satisfy the monthly reconciliation requirement.
3. In an automated dispensing machine/cabinet, does a blind count satisfy the monthly reconciliation requirement?
   1. If the storage area for a schedule II controlled substance is accessed at least once in the month and comparison of the perpetual inventory against the actual inventory occurs, then a blind count would satisfy the monthly reconciliation requirement.
4. What should I do if I find a discrepancy in the perpetual inventory?
   1. Any loss, theft or unauthorized destruction of a controlled substance discovered during the reconciliation shall be reported to the Drug Control Division by a pharmacy or institutional pharmacy not later than seventy-two hours after discovery.  The preferred way to report this loss is to DCP.DrugLoss@ct.gov.The Drug Enforcement Administration (DEA) should also be notified on a DEA 106 form.
5. For controlled substances in schedules III, IV, and V, is a perpetual inventory and monthly reconciliation also required?
   a.  No.  The perpetual inventory and monthly reconciliation requirements apply only to schedule II controlled substances.  However, a licensed pharmacy or an institutional pharmacy is permitted to have a policy that is stricter than state law.  For instance, the pharmacy’s policy could require schedule II controlled substances to be reconciled less than monthly or for perpetual inventories and reconciliations to also be performed on controlled substances in schedules III, IV and V.  In any event, as long as the pharmacy’s policy mirrors state law or is stricter than state law, said policy would govern the pharmacy’s inventory and reconciliation process.