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Report Theft/Significant Loss of Controlled Substances

This procedures also contains:

Contact information for: UMDPS, UMOR CS Monitors, DEA, & the State of Michigan

Best practice information

Links to the DEA procedures & DEA Form 106

Print version of the procedure

The SOM licensee/DEA registrant is responsible for prompt reporting of a controlled substance theft or significant loss.   UMOR Controlled Substance Monitors will assist the licensee/registrant throughout the reporting and investigation process. 

Immediately upon discovery:

1.  Notify the U-M Division of Public Safety & Security (University Police).  The University Police will take a report and conduct an investigation.

2.  Obtain the following information from the University Police:

  • UMDPS report number
  • Investigating officer's name
  • Officer's phone number

3.  Notify the UMOR Controlled Substance Monitors.  

Within one (1) business day of discovery:

1.  Fax the following information in a written memo to the DEA Detroit Field Office:

  • The specific controlled substances involved, including specific amounts lost or diverted
  • Indication as to whether the loss or theft can be associated with specific individuals, or whether the loss or theft can be attributed to unique activities that may take place involving the controlled substances
  • Indicate any pattern of losses over a specific time period (whether they appear random or are the result of efforts taken to resolve the losses)

2.  Complete and submit the online DEA Form 106.  Print a completed copy for your records.

3.  Call the State of Michigan Bureau of Health Professions to report the theft or loss.

4.  Fax a copy of the completed DEA Form 106 to the State of Michigan

Best Practices & Actions (document vs. report)

“Significant loss” is a subjective term, not defined by the federal Controlled Substance Act.  Consider the following when determining whether to report a loss:

  • The quantity of loss in relation to business type (actions: document non-significant loss; report significant loss)
  • Whether the loss is associated with theft (action: report)
  • Whether the loss is waste during use of the substance in laboratory (action: document)
  • Pattern of losses over time (action: report)
  • The substance’s potential for diversion or theft (action: report)

Non-significant loss caused by miscounts or clerical errors must still be documented on the usage logs and must be recorded on the DEA Form 106.  Keep the completed DEA Form 106 with the controlled substance records for a minimum of two (2) years.  Do not send to the DEA.

References and Resources

Controlled Substance Procedures

Questions?

U-M Public Safety

(734) 763-1131 (non-emergency)

UMOR Controlled Substance Monitors

(734) 764-2003 or (734) 764-2004
CS-monitors@med.umich.edu

Emergency pager - phone option:  734-936-6266, enter 31685, then enter your return phone number

Emergency pager - web option:  Go to https://uhmspaging.med.umich.edu/homepaging/PagingSend/search.aspx; enter cs-monitors in the Serarch field; click 31685; enter your message with return phone number in the non-clinical form.

DEA Detroit Field Office - Diversion

General Fax:  (313) 226-7545
Phone: (313) 226-7537

State of Michigan Bureau of Health Professions

Phone:  (517) 373-1737
Fax:  (517) 373-4886
bhpinfo@michigan.gov