Countra replaces the paper binder for ambulatory surgery centers that handle controlled substances in-house. One record holds both halves of the count: what left your stock, and what was accounted for afterward, from delivery into inventory through witnessed waste.
Countra is controlled-substance documentation and monitoring software for ambulatory surgery centers that handle controlled substances in-house, without a hospital pharmacy behind them.
Countra replaces the paper binder. Your team logs delivery into inventory, checkout for a case, administration, and witnessed waste as it happens, and Countra keeps your perpetual inventory current and balances it against your physical count. Its AI-assisted monitoring compares usage, waste, and sequences of activity against peer patterns and is designed to surface an outlier as an alert for a person to review, a prompt to look closer rather than a conclusion. It works from the safe or cabinet already in your center, with the team already on your schedule.
A flag is a prompt to look closer, not an accusation and not a conclusion. Countra surfaces the pattern with the documentation behind it. The review, and the judgment, stay with you.
The count is arithmetic, and arithmetic needs two numbers. Most centers keep the two numbers in two different places.
On paper, a discrepancy waits for count day to show itself. By then the case is closed, the room has turned over dozens of times, and the trail back to one entry is cold. When the surveyor asks how fast a loss gets detected, the binder's answer is measured in weeks.
A reconciliation needs two quantities: what left your stock, and what was accounted for afterward. The anesthesia record documents the dose, but it is organized by patient and it holds only one half. Your center's own record is the one that has to hold both, and today it usually holds them in two places: a binder for the stock side, and whatever gets written down between cases for the rest.
Controlled-substance records trace back to a registrant, and the record that answers for yours is the one your center keeps.
You do not have a hospital pharmacy or a diversion officer. You have a locked cabinet, a count, and a room that turns over before the paperwork does.
Every controlled substance in your center travels the same path. The top half is what your own record already holds. The bottom half is the half that has to be captured in the middle of patient care.
The only place the two halves have to agree.
When a surveyor reviews your controlled substance records, the CMS State Operations Manual, Appendix L, tag Q-0181, directs them to ask a specific question.
Is the ASC's system capable of readily identifying loss or diversion of all controlled substances in such a manner as to minimize the time between the actual losses or diversion to the time of detection and determination of the extent of loss or diversion?
All drug records are in order and an account of all scheduled drugs is maintained and any discrepancies in count are reconciled promptly.
The guidance puts that reconciliation duty on the licensed healthcare professional your center designates as responsible for pharmaceutical services. It is a question about your system, answered by your own people.
Nobody else gets to answer it for you.
Countra records each step of handling along that chain and keeps the record ready to produce.
If your center is Quad A accredited, the standards already name what Countra is. Standard 6-D-2 accepts your controlled substance record in one of two forms: a sequentially numbered bound journal, or a tamper-proof, secure computer record. Countra is the second form.
From a locked safe or cabinet, with no hospital pharmacy behind you. GI and endoscopy, ophthalmology, orthopedic, pain: if your own team stocks the controlled substances, counts them, and documents the waste, Countra is built for the way you already work.
If you have neither a hospital pharmacy nor a dispensing cabinet, most diversion-monitoring tools were not built for you. Countra was.
The record it keeps is your center's record whether your anesthesia providers are employed by the center or contracted. Your own OR nurses do the documentation in Countra, so the record does not depend on an outside group adopting new software.
Stock is received and logged into your perpetual inventory, with who logged it and when.
The controlled substance is signed out of stock for a specific case. A checkout for a case that is later cancelled, or for a drug that is never administered, stays on the record instead of disappearing between two pieces of paper.
The dose given to the patient is documented, with the name of the person who administered it and the date.
Leftover drug is wasted and a second person co-signs. The co-signature is designed to be captured at the moment of waste, not reconstructed later.
A container that was checked out and never opened goes back into stock, and the return is recorded on the same record as the checkout.
Your perpetual inventory is balanced against your physical count, so a count that will not close is visible in the record, with the entries behind it.
One record from delivery into inventory through witnessed waste, with who signed and when, ready to hand over without a fire drill.
Your perpetual inventory balanced against your physical count, so a count that will not close is visible in the record, with the entries behind it. A reconciliation discrepancy is flagged for review immediately, as the entry is recorded.
The waste and the co-signature are recorded as one step, and the co-signature is designed to be captured at the moment of waste rather than reconstructed later.
Entries lock once recorded. If a correction is needed, it is captured as a new time-stamped entry, so the original is never erased and the full history stays intact.
Generate clean PDF reports of your records on demand: for an unannounced survey, for your accreditation file, or for whoever reviews your reconciliation. Your records are yours.
An ambulatory surgery center that holds a DEA registration has to be able to produce a defined set of controlled-substance records on request: an inventory, a continuing record of what came in and what went out, an administration record naming the person who gave the dose, executed order forms, and any theft or loss reports. Federal rules set the floor. Several states sit above it. This section lists the federal set with its citations, then what Countra records against it, and then what Countra does not do.
Federal law does not require a perpetual inventory. 21 CFR 1304.21(a) closes by saying that no registrant shall be required to maintain one. Perpetual inventory is a practice, and in several states a state requirement, but it is not a federal mandate.
Federal law does not require procedural waste to be witnessed. 21 CFR 1304.21(e) says the destruction of a controlled substance dispensed for immediate administration at your registered location, when it is not fully exhausted, is recorded under 21 CFR 1304.22(c) and need not be maintained on a DEA Form 41. The two-employee witness rule at 21 CFR 1317.95(d) attaches to on-site destruction of stock the center still holds, which is a different record. The witness requirement on procedural waste comes from state rules, accreditation standards and your own facility policy, and it varies.
Federal law is the floor, and many states sit above it, on their own clocks. Depending on the state, that can mean a perpetual inventory kept as a matter of law, reconciliation on a set schedule with a signed certification, a witness and co-signature required on procedural waste, or an inventory cadence faster than the federal two-year rule. The details differ from state to state, and a group operating in more than one state is running more than one set of rules at once. Confirm your own state's requirements with counsel and your state board of pharmacy.
This page describes federal and state requirements in general terms. It is general information, not legal advice. Countra and Autonomous Healthcare, Inc. are not affiliated with, endorsed by, or acting on behalf of the Drug Enforcement Administration, the Centers for Medicare and Medicaid Services, any state board of pharmacy, or any accrediting organization. Confirm every requirement with your own counsel and your state board of pharmacy before you rely on it.
Reviewed and current as of August 28, 2026.
Print this sectionControlled-substance records are legally serious. Here is what stands behind Countra.
Countra's approach to controlled-substance monitoring came out of work supported by the National Institutes of Health and the National Institute on Drug Abuse.
A short demo walks through delivery into inventory, checkout for a case, administration, witnessed waste, and the reconciliation, on the workflow your team already runs.
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