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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 DEA registrant is responsible for prompt reporting of a controlled substance theft or significant loss. The UMOR Controlled Substance Monitoring Team will assist the 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 bpldata@michigan.gov

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)
  • 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

Questions?

U-M Public Safety

(734) 763-1131 (non-emergency)

Controlled Substance Monitoring Program Manager

Kelli Christman
(734) 764-2003

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