Assisted Living Medication Management: Controlled Substances

The Controlled Substances Act (CSA) was enacted into law by the United States Congress as Title II of the Comprehensive Drug Abuse Prevention and Control Act of 1970. The CSA is the legal basis by which the manufacture, possession, and distribution of certain drugs are regulated. A controlled substance is generally a drug or chemical whose manufacture, possession, and use are regulated by the government.

There are five schedules of controlled substances (schedules I, II, III, IV, and V). Classification decisions are based on the drug’s potential for abuse, accepted medical use, and the potential for dependence. Schedule I are drugs with a high potential for abuse and has no currently accepted medical use in treatment in the United States. Schedule II-V drugs are drugs with a current accepted medical use but still have abuse potential. Schedule II drugs have a higher abuse potential than III-V.

Controlled Substances can be stolen and used or sold. In both cases residents are at risk because they do not get their medication or if the person who stole the medications is a caregiver and the caregiver is abusing the medication it can further put the resident at risk due to receiving care from a caregiver under the influence. Facilities should be diligent looking for warning signs from staff and also from family members and others who may come into the facility. Examples include a staff person who always needs to check in the medications, a staff person who is having financial difficulties, a family member who always is there when a new supply of controlled substances comes in, and vendors who come into the facility and want to know how medications are stored. Watching for warnings and combining with other information like pain and medication administration patterns can help determine if further investigation is warranted.

Relevant Regulations

Community-Based Residential Facility (CBRF)
Wis. Admin. Code § DHS 83.37(1)(j)
Wis. Admin. Code § DHS 83.37(3)(g)



1. Do all controlled substances need to be counted?

In a CBRF Wis. Admin. Code § DHS 83.37 (1)(J) requires a daily audit of only schedule II medications. However some facilities that may have issues with diversion may incorporate other schedules of controlled substances into the daily count or may count more frequently.

2. Do controlled substances need to be locked?

In a CBRF Wis. Admin. Code § DHS 83.37(3)(g) requires a separate lock for schedule II medications.

Last Revised: June 21, 2021