A year-end DEA compliance review checklist for veterinary practices
Before December 31, your counts, invoices, access lists, and paperwork should all line up. We know the end of the year comes up fast, so we’ve distilled it into one checklist, in the order that works, with how VetSnap makes each step simpler.
The year-end order
- Clean up records (Early Dec)
- Review people and policies (Mid-Dec)
- Check reporting and disposal (Mid-Dec)
- Perform physical count (Last business day)
- File and start fresh (First week of Jan)
The short version
- Order matters: clean up, review, count, and then file.
- Your last-day count can be your biennial if one is due.
- Print the checklist at the end and give every task an owner.
Why the end of the year is a hard stop
Of all the questions practices bring us in November and December, the most common isn’t how to start the new year, but how to close out the old one. What do we do with this year’s logs? Which records do we keep, and where? What has to happen before December 31?
The answer is a year-end DEA compliance review: a short list with a long tail. Every item on it is simple. Together they touch every controlled substance in the building, every person who can reach them, and every piece of paper that proves where they went. Leave them for the last week of December and they collide with holiday schedules, year-end inventory, and a full appointment book.
Clean up first. Otherwise you’ll be signing a count that doesn’t match your log.
So, order matters. Clean up your records first, then review people and policies, then count, and then file. Below is each step: what it involves, why it matters, and what it looks like in VetSnap.
Step 1: Clean up your records before you count
Early December
- Resolve every unreconciled, unmatched, or flagged log entry so balances are right before anyone counts.
- Close out empty containers, so no finished bottle still shows a balance.
- Investigate every discrepancy and document the cause and how it was resolved.
- Set expired or unwanted drugs aside, label them as awaiting disposal, and keep them out of regular stock.
Why it matters. Federal rules require a complete and accurate record, kept on a current basis (21 CFR 1304.21). A log that is weeks behind going into the count is a log that will not match it.
With VetSnap
- Discrepancies flagged for you in the Reconcile tab.
- Empty list = current logbook.
- Every bottle is tracked from receipt to disposal, so a finished bottle with a balance stands out.
[Image: Reconcile tab with one entry flagged “Fix Needed”]
Step 2: Review people, access, and policies
Mid-December
- Update your authorized personnel list based on current staff, and confirm approvals and signatures.
- Change or retire keys, codes, and PINs for anyone who no longer needs access.
- Review your controlled substance SOP for ordering, receiving, storage, waste, and counts, and update it for this year’s changes.
- Check expiration dates on your DEA registration and any state controlled substance license.
Why it matters. When an investigator asks who could reach a drug, the answer needs to be a list, not a guess. And a lapsed registration is the easiest violation there is to prevent.
With VetSnap
- Every entry tied to a person by signature and PIN.
- Report shows everyone with access, with start and removal dates.
[Image: Reporting menu with Authorized Personnel selected]
Step 3: Check reporting and disposal
Mid-December
- Confirm every PMP submission for the year is complete, if your state requires PMP reporting from veterinarians.
- Dispose of expired or unwanted stock through a DEA-registered reverse distributor. Destroy on site only if it is made non-retrievable, recorded on DEA Form 41, and handled and witnessed by two employees.
- Check for federal and state rule changes from this year. Where they differ, follow the stricter one.
Why it matters. Disposal is where a drug leaves your records, so it needs the same paper trail as the day it arrived. On-site destruction must be recorded on DEA Form 41 and witnessed by two employees (21 CFR 1317.95).
With VetSnap
- PMP Assistant auto-fills from your PIMS and generates your state’s report file.
- Waste needs 2 signatures, every time.
[Image: PMP Assistant showing one log “Missing Information” and one “Ready For File Generation”]
Step 4: Perform physical count
Last business day of the year
- Do a full physical count in every location: main and satellite storage, refrigerators, crash carts, mobile kits, and vehicles.
- Make this count your biennial, if it has been two years since your last one.
- Record the date and whether you counted at the opening or close of business.
- Count open Schedule II containers exactly.
- Have two people count together, so you have a witness. Compare with your log and resolve any difference before anyone signs.
- Start next year’s balances from this count.
Why it matters. Take this count on the last business day of the year, or the last day you’re open. Any business after it changes the numbers, so this is your final close-out count for the year and the line every 2027 record traces back to. The biennial inventory is one of the records DEA investigators specifically check, so taking it from a clean, reconciled count matters (21 CFR 1304.11).
With VetSnap
- Full inventory count with container balances already tracked.
- Guided biennial counts walk you through timing and the registrant’s signature.
- No missing info. Incomplete counts can’t be filed.
[Image: Physical count set to “Biennial, Count at Beginning of Day”]
Step 5: File the year and start fresh
First week of January
- Keep each invoice with its packing slip, as proof of what was ordered and what was received.
- File Schedule II records separately from Schedule III–V records.
- Start new folders for DEA Form 222s (with containers and dates actually received on your copy), Form 41s, and any Form 106s.
- Keep records at least 2 years, longer if your state requires it.
Why it matters. Investigators ask for the purchase side and the usage side together. If those live in different binders, someone has to reunite them under pressure. Federal rules require keeping these records for at least two years, with Schedule I–II records kept separate (21 CFR 1304.04).
With VetSnap
- Containers logged on arrival, with lot and invoice number.
- Schedule II and III–V kept separate automatically.
- Complete audit report in 1 click. Pick the drugs and date range, then print.
[Image: Restock screen with container number and lot number]
The printable checklist
The end of the year is busy enough. We put all five steps in one printable checklist so nothing slips through the cracks. Give every task an owner and check items off as you go.
[Image: Year-end DEA compliance review checklist for veterinary practices, with five steps and how VetSnap handles each]
If this list feels long
It’s because there’s a lot happening. Every item is manageable, but they all land in the same few weeks, on the same few people, at the busiest time of the year. That’s why we put everything in one place, and why our goal is to make each step simpler, so nothing gets missed and your time goes further.
Nobody will be perfect, but effort and consistency go a long way. A log that shows steady, documented work all year, with every count signed and every correction explained, is the record you want in front of you during an audit.
Most of what makes the list long on paper is what VetSnap does as you go: reconciling as entries come in, tracking every container from receipt to removal, and tying every action to a signature. Practices that work that way all year find the same thing:
December is a review, not a rebuild.
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