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What exactly is a biennial narcotic count? Why do we have to perform them? And how are they done?

The word biennial should not be confused with biannual (sound alike look alike alert!). Biennial actually means once every two years, while biannual means two times per year. So the biennial narcotic count is an inventory of controlled substances that is taken once every two years.

Biennial counts should be thought of as a checkpoint. This inventory is a complete accounting of all controlled substances, in the facility, under the ownership of the DEA registrant at the date and time the count is completed. The biennial narcotic inventory is required by DEA Title 21 §1304.11(c) and more information on the regulation can be found here.

Although the biennial count must be completed by the 2nd anniversary of the initial controlled substance inventory and every 2 years thereafter, healthcare facilities may perform the count sooner, or at shorter intervals, if they like.

The protocol for completing the biennial count is very similar to a daily controlled substance count. Below is an example of a biennial count sheet.

Follow these steps to complete your biennial narcotic count.

  1. A biennial count sheet must be completed for all CII controlled substances and a separate biennial count sheet must be completed for all CIII-CV controlled substances. Print two blank forms and complete one for your CII's and one for your CIII-CVs.

  2. A biennial count must be performed for each separate perpetual inventory. For example, if a facility has a "main cabinet" for storage of controlled substances, and several sub-stocks with their own inventory log, a biennial count must be performed for each corresponding inventory log book. Drugs signed out to anesthesia or staff during the day, but returned to a main cabinet at the end of the day, are considered part of that cabinet's inventory- do not complete biennial counts for tackle boxes or "fanny packs".

  3. Two licensed healthcare professionals should complete the count. Both individuals must be present and count the controlled substance inventory together. Both individuals are equally responsible for the accuracy of the count.

  4. The biennial count should be performed at the end of the day after all controlled substances have been returned from anesthesia or satellite stocks.

  5. In general, the same rules apply to the biennial count as the perpetual narcotic log. Figures may not be written over and white out may not be used.

  6. The biennial count must be performed at least once every two years, but may be performed more frequently.

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