Pharmacy Reporting Policy for Controlled Substance Loss or Theft
Summary
The Massachusetts Board of Registration in Pharmacy has issued Policy 2026-01, updating procedures for licensed pharmacies and wholesalers to report confirmed losses or thefts of controlled substances. The policy requires reporting within 7 days of confirmed losses, including those from theft, pilferage, or diversion, regardless of quantity or schedule, and significant losses of Schedule VI substances.
What changed
The Massachusetts Board of Registration in Pharmacy (MA BRP) has issued Policy 2026-01, superseding Policy 2022-01, to clarify and update the reporting requirements for confirmed losses or thefts of controlled substances by licensed pharmacies and wholesalers. The policy mandates reporting within 7 calendar days of confirmed losses, including all losses related to theft, employee pilferage, or diversion, irrespective of quantity or drug schedule. It also requires reporting of all significant losses of Schedule II through V controlled substances and significant losses of Schedule VI controlled substances that must be reported to the Prescription Monitoring Program. Unconfirmed losses and losses due to confirmed dispensing errors are generally not reportable, though documentation and adherence to quality improvement programs are still required.
Pharmacies and wholesalers must submit the Pharmacy Loss of Controlled Substances Report (RLCS) and DEA Form 106 (if applicable) to the Board within the specified timeframe. They must also comply with any other reporting obligations from the DEA, state, and local police. Compliance officers should ensure their internal procedures align with these updated reporting mandates and that staff are trained on the distinction between reportable and non-reportable losses, as well as the documentation requirements for insignificant losses. Failure to comply with these reporting requirements could lead to regulatory action by the Board.
What to do next
- Review and update internal policies and procedures for reporting controlled substance losses or thefts.
- Ensure all staff involved in controlled substance handling are trained on the updated reporting requirements in Policy 2026-01.
- Confirm timely submission of RLCS and DEA Form 106 (if applicable) within 7 days of confirmed losses.
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.
Board of Registration in Pharmacy Policy 2026-01: Loss or Theft of Controlled Substances
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).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. B. All significant losses of Schedule II through V controlled The Commonwealth of Massachusetts substances.All significant losses of Schedule VI controlled substances that are Executive Office of Health and Human Services
Department of Public Health required to be reported to the Prescription Monitoring Program. Bureau of Health Professions Licensure 250 Washington Street, Boston, MA 02108-4619 Adopted: 3/26/26 Page 1 of 2
Tel: 617-973-0960 www.mass.gov/dph/boards
***Do not report unconfirmed losses. Please see DEA Guidance regarding what constitutes a “significant loss”.
- 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 Continuous must comply with all requirements of 247 CMR 15.00: Quality Improvement Program . Supersedes Policy 2022-01 Please direct any questions to: DHPL-OPP.ADMIN@mass.gov
Adopted: 3/26/26 Page 2 of 2
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