Pharmacy Policy on Reporting Loss or Theft of Controlled Substances
Summary
The Massachusetts Board of Registration in Pharmacy has issued Policy 2026-01, updating procedures for pharmacies and wholesalers to report confirmed losses or thefts of controlled substances. The policy requires reporting within 7 calendar days of discovery for all losses related to theft, pilferage, or diversion, regardless of quantity or schedule, and significant losses of Schedule II-VI substances.
What changed
The Massachusetts Board of Registration in Pharmacy has issued Policy 2026-01, superseding Policy 2022-01, to clarify reporting requirements for controlled substance losses and thefts. This policy mandates that licensed pharmacies and wholesalers report confirmed losses within 7 calendar days of discovery. This includes all losses from theft, pilferage, or diversion, irrespective of quantity or drug schedule, as well as significant losses of Schedule II through V substances and significant losses of Schedule VI substances that must also be reported to the Prescription Monitoring Program.
Pharmacies and wholesalers must submit the Pharmacy Loss of Controlled Substances Report (RLCS) and DEA Form 106 (if applicable) to the Board. They must also adhere to DEA, state, and local police reporting mandates. Insignificant losses and losses due to confirmed dispensing errors do not require reporting but must be documented internally. This policy emphasizes the importance of timely and accurate reporting to prevent drug diversion and ensure compliance with state and federal regulations.
What to do next
- Report confirmed losses or thefts of controlled substances within 7 calendar days using the RLCS form and DEA Form 106 (if applicable).
- Document all insignificant losses internally and track for adverse trending.
- Comply with all other DEA, state, and local police reporting requirements.
Archived snapshot
Mar 27, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
The Commonwealth of Massachusetts
Executive Office of Health and Human Services
Department of Public Health
Bureau of Health Professions Licensure
250 Washington Street, Boston, MA 02108-4619
Tel: 617-973-0960
Board of Registration in Pharmacy
Policy 2026-01: Loss or Theft of Controlled Substances
I. Purpose
In accordance with 247 CMR 7.04(2)(g) and 20.03(7), this policy sets forth the procedures for resident Board-licensed pharmacies and wholesalers to report confirmed losses and thefts of controlled substances to the Board of Registration in Pharmacy (Board).
II. Reporting Requirements
Within 7 calendar days of a controlled substance loss or theft as outlined below, the pharmacy or wholesaler must submit to the Board the Pharmacy Loss of Controlled Substances Report (RLCS) and DEA Form 106 (if applicable). The pharmacy or wholesaler must also comply with any other reporting requirements of the DEA, state, and local police.
Pharmacies and wholesalers must report the following types of confirmed losses:
- All losses related to theft, employee pilferage, or diversion no matter the quantity or schedule of the medication.
- All significant losses of Schedule II through V controlled substances.
- All significant losses of Schedule VI controlled substances that are required to be reported to the Prescription Monitoring Program. ****Do not report unconfirmed losses.*
Please see DEA Guidance regarding what constitutes a “significant loss”.
III. Nonreportable Losses
Unless otherwise noted above, insignificant losses do not require reporting. Losses determined to be insignificant after internal investigation must be documented onsite (e.g., logbook, electronic log) and tracked for adverse trending.
Regardless of drug schedule, losses that result from a confirmed dispensing error do not have to be reported. However, the pharmacy must comply with all requirements of 247 CMR 15.00: Continuous Quality Improvement Program.
Supersedes Policy 2022-01
Please direct any questions to: DHPL-OPP.ADMIN@mass.gov
Adopted: 3/26/26 Page 1 of 1
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