Google Sheets or TutelaRx: six questions an inspector can ask

Some sedation practices keep the drug log in a Google Sheet (or Excel). It adds. It’s searchable.

Is it enough? Here are six questions an inspector can ask. Each is answered from a Google Sheet, then from TutelaRx, with the rule linked.

The rules do not name a format. We covered that in who told you the drug log has to be paper.

1. Who gave this dose, and how much?

The rule: 21 CFR 1304.22(c). Each administration record must show the patient’s name and address, the date, and the number of units or volume. It must also show the name or initials of the person who gave it.

From Sheets: a column for each item. The risk is a blank cell. After four sedations, Sheets will save a half-empty row without a word.

From TutelaRx: every entry is tied to a logged-in user. Every entry shows who did it.

2. What is on hand right now, and does it match the safe?

The rule: 21 CFR 1304.21(a). Keep, on a current basis, a complete and accurate record of each controlled substance received, dispensed, or otherwise disposed of. Half a vial of fentanyl left after a case still gets recorded. No DEA Form 41 is needed for that waste (1304.21(e)).

From Sheets: a running balance is a formula. It can break when someone deletes a row or sorts the sheet. Google says changes made by formulas and deleted rows might not show up in a cell’s edit history. So when the count is off, you may not see why.

The rule also wants separate records for each registered location (1304.21(b)). In Sheets, a box of ketamine moving between offices is two rows. A minus on one tab, a plus on the other. Nothing ties the two rows together unless you build that yourself.

From TutelaRx: each office has its own running inventory. The app does the math on every entry. Transfers are tracked on both ends. At 5 p.m. you check that the safe matches the app.

3. Who changed this entry, and when?

The rule: 1304.21(d). The date you record must be the date it happened, not the day you typed it. Paragraph (a) also asks that the record be complete and accurate, on a current basis.

From Sheets: better than most people think. Right-click a cell and choose Show edit history. It shows who last made a direct edit, when, and the old and new values.

But Google lists gaps. Added or deleted rows and columns might not show up. Neither might changes made by formulas. Restoring an earlier version clears the cell history for everything before it.

The file owner can delete unnamed version history, and that cannot be undone. Google caps named versions at 15 per spreadsheet, so you can’t name one a day. Name one at moments that matter, like right after the biennial inventory. The safe rule: never restore, never delete history.

In Sheets, fixing a mistake means typing over it. In TutelaRx, staff enter and doctors approve. Approved entries lock. A void needs a reason, and the trail stays.

4. Where is your last biennial inventory?

The rule: 1304.11. An inventory on the first day you handle controlled substances, then a new one at least every two years. It must be kept in written, typewritten, or printed form at the registered location. It must also say whether it was taken at opening or close of business.

From Sheets: count the safe, type it into a tab, note the date and opening or close. The rule says “written, typewritten, or printed form at the registered location.” A conservative reading: print it and keep it at the office. The hard part is remembering two years from now.

From TutelaRx: biennial inventory support is built in. It prints in the written form the rules require.

5. Where are your Schedule II records, kept apart from the rest?

The rule: 1304.04(f) and (g). Schedule II records are kept separately from all other records. Schedule III through V records may be kept separately, or in a form that is readily retrievable. 1300.01 defines that as records you can separate out in a reasonable time.

From Sheets: keep fentanyl in its own file at each office, never mixed with the Versed and ketamine tabs. Keep the log out of the file with your schedule and supply orders. That is what the plain words ask for. A fair point for Sheets.

From TutelaRx: the drug log is its own record, apart from your charting software and your business files. It holds the running count, the waste with a witness, the transfers, the biennial inventory. Print any date range as the daily inventory sheet inspectors expect.

6. Can I read these records here, right now, and copy them?

The rule: 1304.04(a). Every record must be available for inspection and copying for at least two years. Paragraph (c) says you need not notify DEA to keep records on an in-house computer system.

The rule does not define “in-house,” and it does not address cloud tools either way. We won’t pretend it does.

From Sheets: open the file, show the inspector, print or export. Simple, as long as someone who can open the file is there. To show version history too, that person needs edit permission.

From TutelaRx: print any date range as a binder. You get a full export.

The HIPAA part

A drug log holds patient names and addresses. That is PHI.

Google will sign a HIPAA Business Associate Amendment, and Sheets is on its HIPAA Included Functionality list. But the BAA is only available through a Workspace admin account on a paid services agreement. The legacy free edition can’t accept it. And Google says customers without a BAA must not put PHI in Workspace.

If you have that admin account, accept the BAA before the first patient name goes in. Turn off editors’ ability to change sharing. Require 2-Step Verification. A Workspace admin can.

And no shared logins. One “front desk” account means no entry is tied to a person.

Even then, Google’s own BAA says the customer is solely responsible for compliant use. Signing it is step one. The rest is on you.

TutelaRx includes a BAA with every plan. Each person has their own login and a second sign-in step. Data is encrypted in transit and at rest. It’s built on SOC 2 Type II certified infrastructure.

Where that leaves you

Question	Google Sheets	TutelaRx
Who gave the dose	Columns you fill in	Tied to a logged-in user
Running count	A formula, if nobody breaks it	Done on every entry
Fixing a mistake	Type over it	A void needs a reason
Transfers between offices	Two rows on two tabs, by hand	Tracked on both ends
Biennial inventory	Count it and type it, then print	Built in, prints in written form
Schedule II separate	Its own file	A record of its own
Read and copy on site	Open it, then print or export	Print a binder, full export

Sheets is a real option. A careful office manager with a BAA can run a clean log in it for years.

What Sheets can’t give you without custom code is the approve-then-lock step. Protected ranges can stop an editor from changing cells in place. But the owner can always edit a locked range. And Google’s own docs say protection “shouldn’t be used as a security measure.”

You could build approval and locking with Apps Script. But then you own that code, and so does whoever replaces you. That lock is the product. It costs $250 a month per practice, month to month.

Dr. Eric Egan of Odyssey Oral Surgery & Sedations kept his log on paper before TutelaRx. He put it this way: “You’re already exhausted after surgery, and then you have to do more math, count, and print labels.” A spreadsheet does the math. The policing is still yours.

For scale: the federal civil penalty runs up to $19,246 per violation. An oral surgeon paid $120,000 over recordkeeping, and no diversion was alleged.

Staying on a spreadsheet or paper for now? Download the free log kit. If you would rather have the app keep the record for you, book a 15-minute demo.

Sources

• 21 CFR 1304.04, retention, Schedule II separation, in-house computer systems.
• 21 CFR 1304.11, inventory requirements.
• 21 CFR 1304.21, complete and accurate records kept current, one per location, partial-dose waste.
• 21 CFR 1304.22, records for dispensers.
• 21 CFR 1300.01, definition of readily retrievable.
• Google Docs Editors Help: version history, edit history and its exceptions.
• Google Workspace Updates: cell edit history, what the dialog shows.
• Google Docs Editors Help: protect a sheet or range, protection options.
• Google Docs Editors Help: share files, what editors can do and what the owner can turn off.
• Google Workspace Admin Help: 2-Step Verification, admins can require it.
• Google Workspace Admin Help: HIPAA compliance, the BAA and PHI.
• Google Workspace Admin Help: privacy compliance and records, who can accept the BAA.
• Google Workspace HIPAA Included Functionality, the list that includes Sheets.
• Google Workspace HIPAA Business Associate Addendum, customer responsibility.
• Apps Script overview, what you can build yourself.
• Apps Script Protection class, scripted range locks.
• Apps Script timesheet approval sample, an approval flow you build and maintain yourself.

This post is general information, not legal advice. Check with your state dental board and your DEA field office about your own obligations.