DEA Form 106: Reporting the Loss of Controlled Substances 

Why DEA Form 106 Reporting Matters for ASCs and Healthcare Facilities

In the high-stakes environment of Ambulatory Surgery Centers (ASCs) and healthcare facilities, controlled substances play a vital role in patient care — but they also require strict accountability.

When controlled substances go missing due to theft, diversion, or accidental loss, facilities are required by law to act quickly. Submitting DEA Form 106 is not just a compliance measure; it’s essential to protect patients, staff, and your organization’s license.


Understanding DEA Reporting Requirements

As a DEA registrant, your facility must report any significant loss or theft of controlled substances within one business day of discovery.

Your Legal Obligations Include:

  • Submitting DEA Form 106 (Report of Theft or Loss of Controlled Substances)

  • Maintaining records and investigation files for at least two years

  • Documenting all corrective actions and follow-up measures

The DEA does not define a specific “significant” quantity, but factors to consider include:

  • The actual amount missing

  • Risk to patient care or public safety

  • Likelihood of diversion

  • Local theft or diversion trends

For official guidance, visit the DEA Diversion Control Division website.

Step-by-Step Guide: How to Complete DEA Form 106

Step 1: Immediate Notification

  • Contact your local DEA field office immediately after identifying a loss.

  • Record the date, time, and agent name you spoke with for your records.

Step 2: Access the Form

Step 3: Complete All Required Sections

Provide detailed information on:

  • Your facility and DEA registration

  • Circumstances of the loss (e.g., theft, breakage, in-transit)

  • Drug name, strength, and quantity

  • Law enforcement notifications

  • Corrective actions implemented

Step 4: Submit and Maintain Records

Beyond Reporting: How to Prevent Controlled Substance Losses

While knowing how to file DEA Form 106 is crucial, prevention is even more important.

1. Smarter Inventory Management

  • Use digital inventory tracking systems for real-time visibility.

  • Conduct weekly audits of high-risk drugs (e.g., fentanyl, hydromorphone).

  • Implement a witness verification system for all waste documentation.

  • Investigate discrepancies immediately, not at the end of shifts.

2. Strengthen Physical and Digital Security

  • Install cameras covering storage and disposal areas.

  • Use biometric or dual-authentication access systems.

  • Employ waste disposal systems that make drugs unusable instantly.

  • Schedule routine security assessments to identify vulnerabilities.

3. Create a Culture of Awareness

  • Train staff to spot signs of diversion or substance use disorder.

  • Promote judgment-free reporting for suspicious behavior.

  • Discuss new diversion trends during team meetings.

4. Maintain Strong Documentation Practices

  • Keep comprehensive transfer logs and witness signatures.

  • Store digital audit trails for all drug transactions.

  • Use electronic systems that flag unusual activity or discrepancies.

Supporting Your Team and Staying Prepared

Filing DEA Form 106 can be stressful — especially if diversion by a colleague is suspected. That’s why proactive support and training matter.

MedServe provides:

Conclusion: Protecting Your Facility with DEA Form 106 Compliance

Prompt, accurate submission of DEA Form 106 safeguards your patients, staff, and license — but real protection starts with strong prevention systems.

By pairing DEA compliance with robust controlled substance tracking and team education, ASCs can minimize risks and uphold the highest standards of safety and integrity.

Ensure your facility stays compliant and secure. Connect with MedServe today for expert guidance on controlled substance management and DEA requirements.

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Smarter Control: Why ASCs Need a Controlled Substance Tracking System Now