Michigan Veterinary Controlled-Substance Log Requirements

Controlled-substance records

Veterinary medical records: at least 7 years. Michigan veterinary rules require a veterinarian practicing in Michigan to maintain a medical record for each animal patient, herd, flock, or other group that accurately reflects evaluation and treatment, whether provided in person or through telehealth. Records must be legible and retrievable and may be maintained in a written, electronic, audio, or photographic format. The record must document patient/client identification and location, last veterinary service date, reason for contact, case history/problem, vaccination history if known, exam findings, lab and other reports, diagnostic procedures, procedures including surgery, hospitalized-patient daily progress notes, informed consent when appropriate, diagnostic options and treatment plans, relevant client communication, and prescribed medication. ¹

Michigan requires veterinary medical records to be maintained for at least 7 years from the date of the last veterinary service. Medical records are confidential and may not be released without client consent except as required by law or to protect public health; upon written or oral client request, copies of complete medical records must be provided. ¹

Controlled-substance records: When dispensing controlled substances, keep Michigan's 5-year acquisition, dispensing-log, and disposition records with the federal controlled-substance records and the 7-year veterinary medical record where the same transaction is also part of patient care. ^{2 1}

Inventory and state-specific controls

Michigan requires state controlled-substance licensure for controlled-substance activity. Michigan law defines "practitioner" broadly to include a prescriber, pharmacist, scientific investigator, or other person licensed, registered, or otherwise permitted to distribute, dispense, conduct research with, or administer controlled substances in professional practice or research in Michigan. A person who manufactures, distributes, prescribes, or dispenses a controlled substance in Michigan must obtain a controlled-substance license issued by the administrator, unless the person is otherwise exempted. The state controlled-substance license renews concurrently with the holder's Article 15 professional license when both are held, and the license authorizes activity only to the extent authorized by the license. ^{3 4}

Location tracking matters. Michigan requires a separate controlled-substance license at each principal place of business or professional practice where the applicant manufactures, distributes, prescribes, or dispenses controlled substances. The administrator may inspect the establishment before issuing the license. Treat each brick-and-mortar clinic, mobile-unit home base, and shared controlled-drug cache as a license-mapping item before DEA registration, ordering, relocation, or ownership changes. ⁴

Controlled-substance awareness training is an issuance precondition. An individual applying for or renewing a Michigan controlled-substance license must complete a training in opioids and controlled-substances awareness before applying for the license or renewal. Apart from a transition rule for renewals in the first cycle after January 4, 2019, the department shall not issue a controlled-substance license until the applicant provides proof of having completed the training. The rule names veterinarians expressly: unless licensed only for research on animals (which is exempt from the rule), a veterinarian must complete a controlled-substance training one time during the current license cycle covering all eight required topics — use of opioids and other controlled substances; integration of treatments; alternative treatments for pain management; counseling on the effects and risks associated with using opioids and other controlled substances; the stigma of addiction; utilizing the MAPS; state and federal laws regarding prescribing and dispensing controlled substances; and security features and proper disposal requirements for opioids and other controlled substances and prescriptions. Keep proof of completion for 3 renewal periods plus 1 additional year; the department may select and audit licensees and request documentation, and acceptable proof includes a completion certificate or a self-attestation showing the date, the provider's name, the name of the training, and the individual's name. ⁵

Prescriber duties and in-house dispensing records: A prescriber holding a Michigan controlled-substance license may administer or dispense Schedule II-V controlled substances without obtaining a separate controlled-substance license for those activities, but must keep state dispensing records when dispensing. Michigan requires a dispensing prescriber to keep invoices and other acquisition records for at least 5 years, maintain a separate log of all controlled substances dispensed for at least 5 years, and maintain records of other dispositions for at least 5 years. Before prescribing or dispensing a controlled substance, a licensed prescriber must ask the patient about other controlled substances and record the response in the patient's medical record; for veterinary patients, build that question around the owner/agent intake workflow. ²

PDMP context

Michigan's PDMP is the Michigan Automated Prescription System (MAPS). LARA describes MAPS as Michigan's Prescription Monitoring Program and says it tracks Schedule II-V controlled-substance prescriptions dispensed in or into Michigan. Michigan law requires the electronic monitoring system to include Schedule II-V controlled substances dispensed in Michigan by veterinarians, pharmacists, and dispensing prescribers, and requires a veterinarian, pharmacist, or dispensing prescriber to use the electronic data transmittal process for reporting. ^{6 7}

Veterinary reporting is a real Michigan workflow. MAPS reporting applies to Schedule II-V controlled substances dispensed by a veterinarian unless an exemption applies. The statute exempts a veterinary hospital or clinic when a controlled substance is administered to an animal that is an inpatient, but that exemption does not cover ordinary owner take-home dispensing. Michigan also permits a written waiver for a veterinarian, pharmacist, or dispensing prescriber who is unable to use the electronic monitoring system. ⁷