Narcotic reconciliation for Ontario pharmacies: a worked six-month count
Most explanations of narcotic reconciliation stop at the formula. This one runs it: one drug, one six-month window, the numbers written out, and the three things that most often turn out to be behind a variance — each worked through until it closes.
The setup
Reconciliation compares your physical count of a controlled substance against the expected quantity calculated from your own records:
Expected on-hand = Last count + Purchased − Dispensed − Destroyed.
Variance = Counted − Expected.
The window runs from the day after the previous count up to and including the current count date. A drug’s very first count simply sets the opening balance — there is no baseline to reconcile against yet. (The formula on its own: how reconciliation works.)
In Ontario the Ontario College of Pharmacists expects this at least every six months. Nova Scotia and Prince Edward Island are stricter, expecting narcotics and controlled drugs reconciled monthly, and Alberta, British Columbia, Saskatchewan, Manitoba and Newfoundland & Labrador generally expect a count every three months. The cadence by province, with its sources, is on inventory frequency in Canada and how often Ontario pharmacies must count.
The window: hydromorphone 2 mg tablets, 1 January to 30 June
One drug, one DIN, six months. Everything above the line is a record you already keep; the expected figure is derived from them, and only the last two rows involve anybody counting anything.
| Line | Where it comes from | Tablets |
|---|---|---|
| Closing count, 31 December | carried forward as the opening balance | 400 |
| Purchased, 1 January – 30 June | receipts entered against this DIN | + 1,000 |
| Dispensed, 1 January – 30 June | every Rx recorded against this DIN | − 1,143 |
| Destroyed, 1 January – 30 June | as logged at the time of the count | − 60 |
| Expected on-hand, 30 June | 400 + 1,000 − 1,143 − 60 | 197 |
| Physically counted, 30 June | two people, one counting, one witnessing | 182 |
| Variance | 182 − 197 | − 15 |
Fifteen tablets short. That is the number an inspector would ask about, and it is not yet a loss — it is a question. Three causes come up again and again, and all three are checkable from the records you already hold.
Cause 1: a destruction that was never logged
A partial-fill remainder was destroyed on 12 May, witnessed and signed on paper, and never entered into the system. Expected was therefore calculated as if those tablets were still on the shelf.
Destroyed 60 → 75. Expected 400 + 1,000 − 1,143 − 75 = 182. Counted 182. Variance 0.
It is worth checking first, and it is why a destruction log that lives outside the system is a reconciliation problem rather than a filing one. (See preparing destructions.)
Cause 2: dispenses recorded against the wrong DIN
Two interchangeable products of the same molecule and strength sit side by side. Sixty tablets were dispensed from the stock bottle of one and recorded against the other.
DIN A: counted 60 under expected. DIN B: counted 60 over expected. Across the molecule the two variances sum to 0.
Reconcile by DIN, because that is how the records are kept — but before treating a shortfall on one DIN as a loss, look at the interchangeable products beside it. A shortage and an overage of the same size in the same window are usually one mistake, not two.
Cause 3: a transaction dated outside the window
A delivery of 500 tablets arrived on 29 June; the invoice was dated 2 July and entered on that date. The stock is physically on the shelf and the receipt is not in the window.
Counted 500 over expected. Correct the receipt date to 29 June and the variance closes to 0.
This one is worth chasing precisely because it looks harmless. Left alone it reverses at the next count and shows up then as a 500-tablet shortage, in a window where nothing went wrong. An unexplained overage is a discrepancy like any other — what decides whether something is reportable is whether it can be explained, not which way it went. (More on that: is a narcotic discrepancy reportable?)
When the numbers still do not reconcile
If the drug does not reconcile after you have been through the records, what you have is a loss or a theft, and it is reported to Health Canada’s Office of Controlled Substances within 10 days of discovering it. The regulations time that clock from discovery, not from the day an investigation closes — Narcotic Control Regulations s. 42 and Food and Drug Regulations s. G.03.013 both read “within 10 days of his discovery thereof”, and Benzodiazepines and Other Targeted Substances Regulations s. 72(2) reads “within 10 days after becoming aware”. So investigate promptly: a slow reconciliation spends the window rather than pausing it. The step-by-step, and the Health Canada form, are on reporting a loss or theft.
What you write down
Every one of the three causes above ends in a dated note against the count item: what the variance was, what explained it, and what you corrected. That note is the thing an inspector reads. Keep it with the count and the transactions behind it — in Ontario, pharmacy records run at least 10 years (O. Reg. 264/16 s. 21), well beyond the federal 2-year minimum, and an inspector may ask for the history rather than the most recent count. (See what to keep, and for how long and exportable reports.)
Doing this without the arithmetic
Everything above is one drug. A real count is a few hundred of them, and the slow part is not the counting — it is deriving the expected figure for each one and then finding the transaction behind a variance. NarcCount calculates expected on-hand from the records you already keep, flags every variance, lets you click through to the exact transactions in the window, and produces an inspection-ready report. It assists your reconciliation — it does not replace your dispensing system, the Ontario Narcotics Monitoring System (NMS), or your professional obligations.
The figures in the worked example are illustrative, chosen so the arithmetic closes on the page. This guide is general information, not legal or professional advice. For the authoritative requirements, refer to the Ontario College of Pharmacists and Health Canada.
Sources
- OCP, Designated Manager — Medication Procurement and Inventory Management Policy — College policy the Designated Manager must follow, not a section of a statute. Six months is a minimum, not a schedule.
- College of Pharmacists of BC, PODSA Bylaws s. 23.8(6)(a) — British Columbia only — each province sets its own interval through its own college.
- Narcotic Control Regulations s. 42 (narcotics) — “A pharmacist shall report to the Minister any loss or theft of a narcotic within 10 days of his discovery thereof.”
- Food and Drug Regulations s. G.03.013 (Part G controlled drugs) — The same 10 days from discovery, for a controlled drug rather than a narcotic.
- Benzodiazepines and Other Targeted Substances Regulations s. 72(2) — s. 72(1)(a) names a pharmacist; s. 72(2) sets 10 days “after becoming aware”.
Primary sources for the figures on this page. Regulations change; confirm the current requirement with the source before you rely on it.