Is a narcotic discrepancy reportable? Loss vs. theft vs. an explained variance

When a controlled substance doesn't match your records, the question isn't “are we over or under?” — it's “is the stock really gone?”

• Reporting to Health Canada is triggered by a theft or a loss, not by every discrepancy on a count. A record error is corrected, not reported. Here's how to tell the difference.
• As always, confirm the current requirements with Health Canada and your provincial college; nothing here is legal advice.

What requires a report

Federally, a pharmacist reports every loss or theft of a controlled substance (Controlled Substances Regulations s. 109(2)), and Health Canada's incident list (CS-GD-005 Appendix A, page dated October 15, 2026) sorts the common cases.

• A theft — pilferage by staff, a break-in, a robbery, a grab theft, a forged prescription that was filled, or supplying someone who used another person's identity — is always reportable, and a break-in or robbery should also go to the police.
• A loss that is unexplained when you discover it is reportable.
• So is stock that is gone for a known reason: a tablet dropped, crushed or spilled that cannot be retrieved or destroyed, a dispensing error the patient does not return, or waste beyond normal business practice.
• A record error you can fully account for, a documented miscount, a manufacturer's short-fill in a sealed bottle and an overage are not reported.

Direction doesn't decide it — whether the stock is gone does

It's tempting to assume a shortage is a loss and an overage is harmless. Both shortcuts are wrong.

• An accidental prescription cancellation, for example, reverses the inventory deduction and adds the stock back to your expected on-hand.
• At the next count it reads as physical-less-than-expected, exactly like a loss, even though every unit went to the right patient on a valid prescription.
• It isn't reportable because the stock went exactly where it should and only the record was wrong, not because of the arithmetic.
• Equally, an overage you can't account for is still an unexplained discrepancy worth investigating, not automatically benign.

Health Canada's guidance says don't over-report

Health Canada's guidance is explicit that you should not report discrepancies that can be reconciled with explanations derived from normally-accepted business activities.

• Its own example: a dispensing error, too much or to the wrong patient, that is documented and that the patient returns is not reported; the same error, not returned, is.
• The goal is an accurate, reconciled record — not a report for every number that looks off.

What to do with a record error

When you can trace the variance to a record error, you don't file a loss report.

• You might trace it to a patient and Rx number, an unlogged destruction, brand or DIN switching, or a transaction dated outside the count window.
• You investigate, correct your perpetual inventory so the record matches the physical count, and keep a dated reconciling note recording the cause and the correction.
• That note is the obligation, and it's what an inspector will want to see.

When it is a loss

If the drug still doesn't reconcile after you've investigated, or the stock is gone for a reason that does not bring it back, treat it as a loss.

• Report it to Health Canada's Office of Controlled Substances within 10 days of discovering it, using Health Canada's controlled-substances loss or theft reporting form.
• The pharmacist reviews and submits it (Controlled Substances Regulations s. 109(2)) — and keep patient names and identifiers off the form.
• Thefts go to the police as well.

The bottom line

Investigate first, report second — report what is really gone, and correct what was only a record error. An overage is not reported, but it is still investigated. NarcCount's reconciliation, AI triage, and one-click loss report are built to help you work through exactly that sequence.