One Missing Ketamine Vial and a Request to "Write It Off"
You are the lead technician at a four-veterinarian small animal practice. During monthly reconciliation you find these entries for ketamine 100 mg/mL, 10 mL vials: six vials purchased this month, three logged as "received," four logged as "used," and a handwritten note reading "1 vial broken" with no initials or date. One vial is missing entirely from the shelf. A patient entry dated the 12th shows ketamine drawn for a dog's dental procedure but no dose or volume recorded. Two technicians and all four veterinarians hold keys to the drug safe. When you raise the discrepancy, the practice owner says, "Just write it off as wastage and initial it yourself - nobody audits small clinics." You also notice an open vial of butorphanol with no entry since the 9th.
1. What do you do about the discrepancy, and what do you refuse to do?
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You do not initial the note, and you do not write anything off. A controlled substance log is a contemporaneous record: every entry must describe something that actually happened, at the time it happened, and wastage requires the drug, amount, date, reason, and a witness signature. Backfilling a broken-vial entry you did not see, with your initials, is falsification - it makes you the person who certified an event you cannot attest to, and it obscures a discrepancy that could be diversion.
So: write a memo to the veterinarian in charge describing exactly what you found, with a reconciliation from purchase invoices to log entries. Secure and count the remaining stock with a second person, and record that count. Report to the DEA registrant. If the practice owner is the one instructing you to falsify, that may mean going to another veterinarian, a compliance officer, or ultimately the state board or DEA. Do not accuse a specific colleague without evidence, and do not discuss it in the treatment room. Preserve invoices, log pages, and video if it exists. Falsifying the record is a bigger violation than the missing vial.
2. What specific changes to drug handling and record-keeping would prevent this from recurring?
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Individual accountability beats shared trust.
Require that every drug removal be recorded at the moment of removal, with patient name, dose, and volume - not reconstructed at month end. Wastage must be witnessed and co-signed at the time. Move from initials to a signature plus printed name.
Restrict access: two technicians and four veterinarians holding keys to one safe is an access-control failure. Use a single lock box with a code, change the code when staff leave, and keep a key log. Consider a camera on the safe or individually locked drawers.
Do a surprise blind count monthly - one person counts, a second verifies against the running log, both sign - and reconcile invoices against entries quarterly. Train everyone on the federal two-year record-retention requirement and applicable state rules, put the policy in writing with consequences, and audit the small stuff: an open butorphanol vial with no entry since the 9th is the kind of sloppiness that hides diversion, and it is far easier to fix than to investigate.
3. A DEA investigator arrives and asks for 24 months of records. The practice owner tells you to bring only the last 6 months. How do you handle it?
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You give the investigator everything requested. A DEA investigator or state inspector has statutory authority to examine required records, and the registrant's obligation is to produce them. Withholding or curating records to the last six months is obstruction, and it turns a bookkeeping problem into a federal one.
Tell the owner clearly, once, that you cannot selectively produce records, and ask that the practice's attorney be contacted. Then cooperate and stay factual: provide a private space, produce the full 24 months, and keep a copy of what was provided. Answer questions truthfully and do not speculate about the missing vial - "I don't know; that is why we began a reconciliation" is a complete and safe answer.
Write your own contemporaneous record of the visit: date, names, what was requested, what was produced, and who was present. If the owner keeps pressuring you to withhold documents, that is the point where your obligation runs to the board and to your own license, not to the practice owner.