The State of Michigan requires an annual inventory of controlled substances to “be conducted and submitted to the administrator not more than 30 days before May 1, but shall be conducted and submitted to the administrator not later than 60 days after May 1” (see the regulation: 333.7321). If there are no controlled substances in stock at the registered location at the time of the annual inventory, the licensee/registrant must still report a zero inventory.
1. The inventory shall contain a complete and accurate record of all controlled substances in the possession or control of the licensee on the date the inventory is taken as follows:
2. For each controlled substance in finished form the inventory shall include:
3. For each controlled substance not in finished form (e.g., damaged, defective or impure substances awaiting disposal, substances held for quality control purposes, or substances maintained for extemporaneous compounding) the inventories shall include:
4. A licensee/registrant shall indicate on the inventory record whether the inventory was taken as of the opening or closing of the day that the inventory is taken.
5. A licensee/registrant shall maintain the inventory in a written, typewritten, or printed form. The inventory taken by use of an oral recording device shall be promptly transcribed.
6. A licensee/registrant shall sign and date the inventory record.
7. A licensee's/registrant’s printed name, address, and DEA number shall be recorded on the inventory.
8. Schedule 2 drugs shall be separated on the inventory from all other drugs.
*see the regulations: R 338.3151; 21 CFR 1304.11
You are no longer required to send a copy of the annual inventory to the State of Michigan. You do need to keep a copy of the inventory with your other controlled substance records. This will meet the requirements of the State of Michigan's annual inventory and the federal regulations for a biennial inventory (see the regulation: 21 CFR 1304.11).