Georgia Veterinary Controlled-Substance Log Requirements

Controlled-substance records

Veterinary medical records: at least 3 years. Georgia minimum standards require complete, accurate, legible records on all animals or animal groups, including owner information, animal identification, and veterinary care; patient records including diagnostic imaging and other patient data must be maintained for at least 3 years by the veterinary facility where treatment occurred, or by the veterinarian if treatment was not performed at a veterinary facility. ¹

Georgia unprofessional-conduct rules also require the veterinarian to prepare and maintain records reflecting care and treatment; required content (the rule's list is expressly not exhaustive) includes owner contact information, attending veterinarian/staff, patient identification, exam/treatment/custody dates, history, presenting complaint, vaccination history, physical exam findings including temperature and weight, lab reports, medication prescribed or recommended with dose/strength/frequency, anesthesia and vital-sign monitoring when applicable, surgical details, progress/disposition/client communications/home-care instructions, differential diagnoses, and radiographs with interpretations. Records must be readily retrievable, contemporaneous, promptly filed, kept for 3 years after the patient's last visit, and provided to the owner within 10 business days after written request. ²

Controlled-substance records: Georgia statutory text requires persons registered to manufacture, distribute, or dispense controlled substances to keep complete and accurate records of all controlled substances on hand, received, manufactured, sold, dispensed, or otherwise disposed of, in conformance with federal requirements and Board of Pharmacy rules. Georgia practitioner-dispensing rules require prescription drug orders to be maintained for 2 years from the fill date, but keep records longer when the same record is also part of the 3-year veterinary patient record or the federal controlled-substance record set. ^{3 4}

Inventory and state-specific controls

How Georgia's Controlled Substances Act reaches veterinarians. The current definition of "practitioner" in O.C.G.A. 16-13-21(23)(A) enumerates "[a] physician, dentist, pharmacist, podiatrist, scientific investigator, or other person licensed, registered, or otherwise authorized under the laws of this state to distribute, dispense, conduct research with respect to, or administer a controlled substance in the course of professional practice or research in this state" — veterinarians are not in the enumerated list and fall under the residual "other person licensed" language rather than being named. Where Georgia statutes address veterinarians expressly is elsewhere: O.C.G.A. 16-13-35(g)(2) registers licensed veterinarians under the Act's registration article (next paragraph), and O.C.G.A. 16-13-41(g) names veterinarians among the practitioners eligible to dispense. "Dispense" means delivering a controlled substance to an ultimate user or research subject by or pursuant to a practitioner's lawful order — including the prescribing, administering, packaging, labeling, or compounding necessary to prepare the substance for that delivery — and also covers the delivery of a controlled substance by a practitioner acting in the normal course of his or her professional practice and in accordance with the Act, or delivery to a relative or representative of the person for whom the controlled substance is prescribed. Separately, the defined term "dispenser" — the term that drives PDMP reporting — means a person licensed to dispense or deliver a Schedule II-V controlled substance to the ultimate user in this state, and it excludes, among others, "[a] practitioner or other authorized person who administers such a substance," licensed hospital pharmacies, institutional pharmacies, and Department of Corrections pharmacies; see the PDMP section's flag box for how this bears on in-house dispensing. ^{5 6 7}

State controlled-substance registration: Georgia-licensed veterinarians are registered by operation of law. O.C.G.A. 16-13-35(a) requires every person who manufactures, distributes, or dispenses controlled substances in Georgia to obtain an annual registration issued by the State Board of Pharmacy — but subsection (g)(2) provides that persons "licensed as a physician, dentist, or veterinarian under the laws of the state to use, mix, prepare, dispense, prescribe, and administer drugs in connection with medical treatment" "are registered under this article and are exempt from the registration fee and registration application requirements of this article". The same exemption covers an employee, agent, or representative of the veterinarian acting in the usual course of employment and not on his or her own account, and it is nullified if the underlying license is suspended or revoked. Practical effect: a veterinarian holding a current Georgia license does not file a separate Georgia controlled-substance registration application or pay a state registration fee; federal DEA registration (covered in the federal baseline) remains required. The Board of Pharmacy's auto-registration rule, Rule 480-20-.01, is a separate provision covering persons and firms holding Georgia Board of Pharmacy licenses or permits (pharmacists, pharmacy interns, pharmacies, manufacturers, wholesale distributors, researchers, reverse distributors); it does not list veterinarians, whose registered status comes from the statute above. A registered physician, dentist, veterinarian, or podiatrist authorized by Georgia to dispense controlled substances may dispense if the practitioner complies with all recordkeeping, labeling, packaging, and storage requirements imposed on pharmacists/pharmacies and the requirements of O.C.G.A. 26-4-130 (26-4-130's renewal-time notice duty is covered under "Notification of intent to dispense" below). ^{6 8 7}

Practitioner dispensing requirements: Georgia pharmacy rules define "practitioner" or "dispensing practitioner" to include a licensed veterinarian, and require all practitioners who dispense drugs to comply with recordkeeping, labeling, packaging, and storage requirements for those drugs. A dispensing practitioner must write a prescription drug order for each dispensed drug; for controlled substances, the order must include the dispensing practitioner's name, address, and DEA number. Dispensed-drug labels must include date and serial number, patient name, prescribing practitioner, dispensing practitioner name/address/telephone, drug name/strength, directions, expiration date, and any other DEA/FDA-required information. ⁴

Notification of intent to dispense (at license renewal): Georgia statute imposes this notice duty directly on all dispensing practitioners. Under O.C.G.A. 26-4-130(e), "[a]ny practitioner who desires to dispense drugs shall notify, at the time of the renewal of that practitioner's license to practice, that practitioner's respective licensing board of that practitioner's intention to dispense drugs," and 26-4-130(a)(2) defines "practitioner" for this purpose to include a person licensed as a veterinarian. The licensing board then notifies the Georgia State Board of Pharmacy; the notification includes the practitioner's name and address, state professional license number, DEA license number, and the name and address of the office or facility from which the drugs will be dispensed plus the address where all records pertaining to those drugs will be maintained. The section does not apply to practitioners who provide manufacturer's samples of drugs to their patients at no cost. The Georgia State Board of Veterinary Medicine applies this duty to all dispensing veterinarians: its published renewal guide states that "[a]t the time of license renewal, licensed Veterinarians are required to notify the Georgia State Board of Veterinary Medicine of their intention to dispense drugs" if they desire to dispense any drugs and/or controlled substances, citing O.C.G.A. 26-4-130(a)(1) & (2) and 26-4-130(e), and instructs all licensed veterinarians to download the Board's "Notice of Intent to Dispense" form and submit it with renewal materials if they answered yes to the renewal question about holding a current DEA number and intending to dispense, or obtained a DEA number during the biennium (two-year renewal cycle). The Board of Pharmacy's practitioner-dispensing rule carries the same renewal-time notice: under Rule 480-28-.03(1), "[a]ny practitioner who intends for his/her agent to dispense drugs shall notify, at the time of the renewal of that practitioner's license to operate, that practitioner's respective licensing board of that practitioner's intention to dispense drugs," with notification content mirroring the statute's (name/address, state license number, DEA number, dispensing facility and records addresses). Although the rule's wording is framed around dispensing through an agent, the statute it sits under reaches any practitioner who desires to dispense, and the veterinary board's guidance applies the notice to all dispensing veterinarians — treat the renewal-time notice as applying whenever the practice dispenses. ^{9 10 4}

PDMP context

Georgia's PDMP monitors controlled-substance prescribing and dispensing. DPH's program page says Schedule II-V prescription information must be entered into the Georgia PDMP within 24 hours after dispensing, and pharmacies must file a zero report for days closed or with no Schedule II-V prescriptions filled. Georgia's PDMP rule likewise requires a "dispenser" to transmit prescription information electronically for each Schedule II-V controlled-substance prescription dispensed in Georgia within 24 hours, and to file a zero report if no prescriptions are dispensed within a 24-hour period. ^{11 12}

For veterinarian access/registration, the Georgia PDMP rules define "prescriber" to exclude a veterinarian, and DPH's registration FAQ answers "No" to whether veterinarians have to register in the Georgia PDMP. Do not build a routine Georgia PDMP query workflow for veterinarians unless the practice has separate written guidance requiring it. ^{12 13}