Biennial inventory
A complete physical inventory of all controlled substances on hand at least once every two years, with a written record maintained for at least two years — drafted and reconciled against purchase and dispensing records.
The most rigorous DEA compliance pack a veterinary practice can receive.
VetLedger assembles a documentation-complete controlled-substance reconciliation and audit-readiness pack — every purchase record reconciled, every dispensing log verified, the biennial inventory drafted, and, when a theft or loss occurs, the DEA Form 106 and one-business-day notification — checked against federal and state recordkeeping requirements before a licensed pharmacist or former DEA diversion investigator certifies it.
Every subsection of 21 CFR 1304.11 & 1301.76(b)Purchase-to-physical reconciliation, gate-checkedDEA Form 106 drafting within 45-day clockPharmacist or former DEA investigator certification5-business-day SLA
Why packs fail
A single unreconciled discrepancy can trigger a five-figure fine.
A veterinary practice's DEA compliance is only as strong as its reconciliation. Miss a purchase invoice, misrecord an administration, skip the biennial inventory, or fail to report a theft within one business day — and the practice faces civil penalties that routinely exceed $1 million in aggregate.
In August 2025, a federal court entered a $956,709 default judgment against a veterinarian who could not account for 9,796 dosage units of oxycodone and hydrocodone. The average practice has 11 potential DEA infractions at any given time, according to a named compliance firm's survey.
Most practices run this by hand, from memory, once or twice a year. The regulations have not been read end-to-end since the last audit. That is exactly where compliance gaps hide.
VetLedger exists to close that gap with a single, exhaustive standard applied identically to every file.
11
average potential DEA infractions per practice (per named compliance firm's survey)
The benchmark
Measured against the letter of the regulation — subsection by subsection.
We do not summarize the law and hope. Every pack is scored against a versioned rule pack tied to the exact text of 21 CFR 1304.11, 1301.76(b), and related DEA recordkeeping requirements. These are the provisions each pack is held to.
Theft/loss notification
Notification to the DEA within one business day of discovering a theft or significant loss, followed by a complete DEA Form 106 within 45 calendar days — drafted and timed to the federal clock.
Recordkeeping requirements
Complete and accurate records of receipt, administration, dispensing, and disposal of controlled substances, reconciled against distributor invoices and physical counts.
Inventory contents
The inventory must include the name, dosage form, strength, and quantity of each controlled substance, verified against DEA Schedule classification.
Maintenance of records
All records must be maintained for at least two years and be readily available for inspection — the pack includes a recordkeeping checklist and retention schedule.
Disposal records
Records of disposal of controlled substances, including the method and date, reconciled against reverse distributor documentation and witness signatures.
How a pack is built
Intake to pharmacist certification, with deterministic gates the AI cannot overrule.
AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A licensed pharmacist or former DEA diversion investigator certifies every release. That order is never reversed.
01
Compliance Gap Scan
Upload purchase invoices, dispensing logs, and physical count records. We return a free completeness read: which regulatory elements and reconciliations you already have, and which are missing.
02
Evidence & record ingestion
As your authorized clerical agent, we ingest distributor invoices (Covetrus, MWI, Patterson, Henry Schein), administration/dispensing logs, and physical inventory sheets, and build a reconciled expected-balance ledger per drug and DEA schedule.
03
Grounded drafting
The biennial inventory report, audit-readiness narrative, and — if triggered — the DEA Form 106 and one-business-day notification are drafted from your validated data and the CFR rule pack into field-locked templates — no legal opinions, no invented facts.
04
Deterministic completeness gates
Purchase records reconcile to dispensing logs to the dosage unit; the biennial inventory date is verified; the theft/loss notification clock is computed; any discrepancy above materiality threshold blocks release.
05
Pharmacist / investigator certification
A licensed pharmacist or former DEA diversion investigator reviews the exception queue and certifies the pack. High-value or complex cases route to senior review.
06
Delivery
You receive the pack: reconciled ledger, biennial inventory report, audit-readiness checklist, DEA Form 106 (if applicable), notification draft, and a compliance calendar — ready for the practice to submit under its own name.
The bar we hold
Rigor you can measure.
100%
Pharmacist-certified
No pack ships without a licensed pharmacist or former DEA investigator signature.
5 days
Standard SLA
From complete intake to certified pack.
<1%
Critical-defect target
Tracked against a gold-standard pack library.
4
Reconciliation sources
Purchase invoices · dispensing logs · physical counts · disposal records, every applicable file.
Why VetLedger
Built to be the most thorough option a practice has.
Documentation-complete, by design
The deliverable is completeness itself — every regulatory element and reconciliation accounted for or explicitly exception-coded. Nothing is left implicit.
Deterministic, not vibes
The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.
In its lane, on purpose
We prepare documentation and run reconciliations as your clerical agent. We never provide legal advice, practice veterinary medicine, or interact with the DEA on your behalf.
Engagement
Flat fee, per certified pack. No hourly billing, ever.
Simple, predictable, and aligned with a documentation standard — not an open-ended consulting engagement.
- A free Compliance Gap Scan before you commit — see exactly what is missing.
- One flat fee per certified Reconciliation & Audit-Readiness Pack; disclosed pass-through search fees.
- Optional fixed-fee attorney review for complex or high-exposure matters.
- Optional Incident Add-on for DEA Form 106 and one-business-day notification drafting, pre-timed to the federal clock.
FAQ
Questions, answered precisely.
Is VetLedger a law firm?
No. VetLedger, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for complex or high-exposure matters.
Do you contact the DEA or file forms on my behalf?
Never. VetLedger is not a legal representative and does not communicate with the DEA or file forms on your behalf. The practice remains the registrant and the party responsible for submitting all notifications and reports.
What makes a pack 'complete'?
Completeness is defined by the regulations: purchase records reconciled to dispensing logs to physical counts, the biennial inventory drafted per 21 CFR 1304.11, theft/loss notification drafted per 1301.76(b), and all discrepancies resolved or exception-coded. Deterministic gates enforce each one before certification.
How fast is it?
The standard SLA is five business days from complete intake to a certified pack. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per certified pack, plus disclosed pass-through search costs. No hourly billing and no percentage of any fine avoided or recovery.
See what's missing before it costs you a fine.
Start with a free Compliance Gap Scan. Send your purchase invoices, dispensing logs, and physical count records and we'll return a completeness read against every subsection of 21 CFR 1304.11 and 1301.76(b).
Documentation-completeness service · not legal advice · the practice submits every report.