What Happened
Best Veterinary Care, doing business as Valley Center Veterinary Clinic in San Diego County, California, paid $125,000 after a DEA audit found the clinic could not account for controlled substances in its inventory.
The settlement arose from a DEA investigation into suspected illegal activity at the clinic. Based on an inventory audit and other investigative activity, the government concluded that Best Veterinary Care violated the Controlled Substances Act from 2020 through 2022 by failing to control its inventory of controlled substances, failing to maintain complete records, and failing to maintain effective controls to guard against theft and diversion.
The unaccounted-for inventory included pills of the benzodiazepines alprazolam (marketed as Xanax) and diazepam, as well as tramadol, an opioid. In addition to paying $125,000 to resolve the government's claims, the clinic entered into a Memorandum of Agreement with the DEA requiring it to adopt additional measures to handle controlled substances properly and safely going forward.
What Went Wrong
- Inventory counts didn't reconcile with records. A DEA audit, not an internal control, identified that pills of multiple controlled substances were unaccounted for.
- Controls to prevent theft and diversion were inadequate. The government specifically alleged the clinic lacked effective safeguards against staff theft or diversion of its controlled-substance stock.
- Veterinary settings received less scrutiny than human health care sites. Controlled substances used in veterinary practice carry the same abuse and diversion risk as those in human medicine but are sometimes subject to less rigorous internal tracking.
How It Could Have Been Prevented
- Conduct regular physical inventory counts of all controlled substances and reconcile them against dispensing and purchase records.
- Apply the same access controls and accountability logs used in human health care settings to veterinary controlled-substance storage.
- Investigate and document any discrepancy between recorded and physical inventory immediately rather than waiting for an external audit.
- Train all staff with access to controlled substances on DEA recordkeeping requirements specific to veterinary registrants.
Related Guidance
- Regulatory Guide — DEA recordkeeping and inventory-control requirements for registrants.
- 15 Red Flags of Drug Diversion — Inventory and recordkeeping indicators of diversion risk.
- Diversion Prevention Checklist — Self-assessment adaptable to veterinary controlled-substance storage.
- More Diversion Case Studies — Other controlled-substance recordkeeping settlements.