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The SOM licensee/DEA registrant is responsible for prompt reporting of a controlled substance theft or significant loss. The UMOR Controlled Substance Monitor 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 Monitor
Within one business day of discovery:
1. With assistance from the UMOR CS Monitor, notify the DEA Detroit Field Office and include the following information:
- 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.
4. Email a copy of the completed DEA Form 106 to the State of Michigan at email@example.com
“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)
- Is the loss is associated with theft? (action: report)
- Is the loss waste during use of the substance in laboratory? (action: document)
- Are there patterns of loss over time? (action: report)
- Does the substances have a high potential for diversion or theft? (action: report)
Non-significant loss caused by miscounts or clerical errors must still be documented on the usage logs, including a short explanation and the user initials.
References and Resources
U-M Public Safety
(734) 763-1131 (non-emergency)
UMOR Controlled Substance Monitor
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.