Drug diversions are not only a regulatory issue, they can also lead to patient safety issues. Most diversions happen with controlled substances, but did you know there are risks and liabilities beyond your narcotic box? Proper medication management is critical from both a regulatory and clinical standpoint. Do you know what steps to take to maintain regulatory compliance and to keep your staff and patients safe?
Drug diversions take many different forms and have more implications than just compliance with the regulations of the Drug Enforcement Administration (DEA). Perhaps it’s a patient who does not receive adequate pain relief or is exposed to an infectious disease from a contaminated vial or needle. Maybe it’s an impaired provider who delivers unsafe care while under the influence. All of these scenarios put patients at risk. In addition to patient risk, the facility also faces potential harm to its reputation along with potential litigation, which could cause additional financial losses.
Drug diversions are happening with increasing frequency. If you have not experienced one, you know someone who has. The opioid crisis has made them more prevalent, and facilities need to work more diligently to help prevent them. As I wrote in a recent post titled “Opioid Misuse Remains a Priority”, a facility that is lacking a system or an expert consultant pharmacist to help them implement and oversee processes, runs a greater risk of diversion and misuse. Diversions increase facility liability in several ways. Below we discuss things to be on the lookout for and steps you can take to minimize the risk of a diversion in your facility.
Ten potential signs of diversion: This is not a comprehensive list, but a good place to start. Work with your pharmacy consultant to develop a complete list and put in place processes to deal with them.
- Controlled substance count is incorrect.
- A verbal order is noted, but not signed by the physician.
- The product container is compromised.
- Prescription pads are missing.
- Vial or syringe contents are replaced with saline.
- Automated dispensing machines show evidence of discrepancies or overrides.
- Wasting of medications is not witnessed.
- Expired controlled substances are missing.
- Falsification on documentation.
- Unapproved use of DEA-222 forms to order medications.
How to prevent drug diversion: There is no foolproof way to prevent all diversions. Every facility is different and should have a thorough evaluation performed by a pharmacy consultant to determine points of weakness and develop safety systems.
Below are three steps every facility can take to reduce risks:
- Foster a culture of prevention: Working with your pharmacy consultant, develop systems to prevent diversion. Start by having a complete and consistent documentation system. This system should be able to track the movement of all controlled substances within your facility. Also, minimize the number of people who have access to controlled substances and properly document all accountability.
- Develop safety systems: Start by random audits of your controlled substance records. Track and trace medications as they are received, dispensed, administered, and wasted. Consider adding additional safety features such as video cameras in areas where controlled substances are stored.
- Act quickly: If you suspect a diversion has taken place, act quickly to minimize losses and then to report the loss to the appropriate authorities. Again, this is an area where your pharmacy consultant can be an invaluable resource.
As the opioid crisis continues to evolve, facilities who are prepared and always vigilant about controlled substance diversions, will be most successful at enhancing the safety of their patients and staff. We recommend developing processes and continually auditing them to keep them relevant and current. If you don’t have a good system in place, are unsure about your processes, or need someone to audit and set them up for you, please reach out to us.
The Consultant Pharmacists at OctariusRx provide guidance on safe medication management, survey readiness and cost savings to ambulatory healthcare facilities/surgery centers, senior care facilities and pharmacies. We also help individual patients optimize their medications to improve their quality of life and save money. Contact us for assistance.