Monthly Reconciliation SOP

How to run, review, certify, and archive your monthly controlled-substance inventory reconciliation — and when to escalate to a DEA-106.

When to reconcile

DEA regulations require a biennial physical inventory; however, best practice — and most state veterinary board guidance — requires a monthly controlled-substance reconciliation. VetRx Ledger automates the computation; your team provides the physical count and sign-off.

Scheduling tip:Perform reconciliation on the last business day of each calendar month. Block 30–60 minutes on the DEA registrant's calendar. The DEA registrant must be present or must countersign the completed report.

Step 1 — Run a blind count

Before opening the reconciliation report, a designated tech performs a fresh blind count (see Draw & Waste SOP for procedure). The blind count must cover every C-II–V vial tracked in VetRx Ledger.

Step 2 — Generate the reconciliation report

Navigate to Reconcile in the top navigation.
Select the reporting period (current month defaults).
Click Run Reconciliation. VetRx Ledger will:
- Sum all DRAW, WASTE, REVERSAL, and ADJUSTMENT events for the period
- Compute the expected closing balance for each vial/lot
- Compare against the most recent BLIND_COUNT entry
- Verify the hash chain integrity for all events in the period
Review the vial summary table. Any row with a non-zero discrepancy column is flagged.

Step 3 — Investigate discrepancies

Discrepancy	Likely cause	Action
±0.01–0.1 mL	Rounding, meniscus, dead-space draw	Document in notes; accept if consistent
±0.1–1 mL	Data-entry error, missed waste event	Review event log; add ADJUSTMENT with reason; DVM sign-off
> 1 mL or > 5%	Diversion risk, systematic error, broken vial	Escalate to DEA registrant; consider DEA-106; document chain of events
Chain integrity FAILED	Data tampering, system error	Do not certify; contact VetRx Ledger support immediately

Step 4 — Download the PDF report

Click Download PDF on the reconciliation page. The report includes:

Period, org, clinic, and report generation timestamp
Chain integrity badge (Valid / Failed)
Per-vial summary with drawn, wasted, reversed, computed balance, and discrepancy columns
Signature blocks for preparer and DEA registrant

Print two copies: one for the binder, one for the DEA registrant's records. Both parties must sign the paper copy within 5 business days of the period end.

Step 5 — Archive

Retain signed reconciliation reports for a minimum of 2 years per 21 CFR 1304.04(a). VetRx Ledger also exports the chain-of-custody JSON package from Ledger → Verify → Export JSON — archive this alongside the signed PDF for electronic verification if the paper copy is ever challenged.

Escalation: Filing a DEA Form 106

If your investigation identifies a significant loss (unexplained variance > threshold, or any suspected diversion), you must file a DEA Form 106 within one business day of discovery. See the DEA Compliance Reference for the exact threshold and filing instructions.

VetRx Ledger can generate a DEA-106 draft pre-populated with vial, lot, quantity, and event data from the ledger. Navigate to DEA 106in the sidebar to generate the draft. You must review, complete, and submit the form through the DEA's official online portal — VetRx Ledger does not file on your behalf.

Download Printable SOP Template

Download this SOP as a formatted PDF to print, sign, and file in your physical controlled substance logbook. Fill in your practice name and DEA registration number before posting. Keep a signed copy on file per 21 CFR §1304.04.

⬇ Download Monthly Reconciliation SOP PDF

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