Controlled Substance Transfer Procedures

If needed, researchers with an active DEA registration for their laboratory can transfer small quantities of their current controlled substance inventory to other registered researchers at the University of Michigan.

The quantity to transfer must be kept to a minimum since federal regulations restrict the transfer of controlled substances to 5% of a registrant's annual total controlled substance inventory or usage.

Transfers are restricted to registered researchers within the University of Michigan, Ann Arbor and regional campus. Non-affiliated outside institution transfers are not permitted.

Each registered location must have an active DEA registration for Schedule II-V controlled substances (Schedule I controlled substances require a separate MI researcher controlled substance license and a DEA 225 registration).

A Research Controlled Substance Transfer Request form must be completed to document the transaction. The completed transfer request form can be used as an invoice.

Transactions of controlled substances transferred to another Departmental or Individual Registrant must include all of the following information and be maintained in the appropriate records of both the receiver and supplier:

• Name, address, and DEA registration number of receiver.
• Name, address, and DEA registration number of supplier.
• Name, concentration, and quantity of controlled substances transferred.
• Distribution or transfer date.

A DEA 222 order form must be used for Schedule I or II agents. The receiving Registrant must submit attached copies 1 and 2 to the Registrant supplier. Supplier must retain Copy 1 and submit Copy 2 to DEA. (See DEA Form 222 Instructions).

The completed transfer request form (or a copy) must accompany any packages containing controlled substances when transferring controlled substances from one registered site to another registered site.

Upon delivery, sign and date the transfer form. File the transfer form with inventory records. Distribution or transfer records must be kept for two years.

Secure and update all newly received controlled substances into the perpetual inventory upon delivery. Receiving registrant must complete copy 3, DEA Form 222 if receiving Schedule I or II substances. Update DEA Form 222 Usage Log if utilizing to track DEA 222 forms.

Registrants can only transfer up to 5% of their annual total controlled substance dosage units (purchased or administered) to other registrants in the University without having to acquire a separate distributor registration.

Intra-University Transfer Form