How to prevent drug diversion is something I spend significant time thinking about and talking about with my facilities.
The ongoing opioid epidemic, along with staffing shortages affecting all facilities, has greatly increased the risk. Whenever I have an opportunity to speak on this topic, I make it a point to remind everyone to expect diversion and develop systems before it happens. Are you taking steps to protect your patients and reduce your liability?
The topic of properly handling controlled substances is always at the forefront of any discussion on compliance, but it extends far beyond just a paper trail. Having a compliant policy and good documentation is only the beginning of regulatory compliance, mitigating risks for patients and liability for facilities.
What are some of the common points of diversion?
Diversion most commonly takes place during administration and disposal, but there are many other points susceptible to illicit activities:
- Ordering: Purchase orders can be removed from your records, or DEA-222 forms are stolen or used without permission.
- Receiving: Falsifying documents or replacing products with other products.
- Prescribing: Verbal orders that are not verified by the prescriber or prescription pads can be stolen to later divert medications.
- Administration: Medications can be documented as administered, but actually are not given to the patient, or waste of partial doses is not witnessed.
- Disposal: Expired medications are properly accounted for and are diverted, or medications are disposed of in the sharps container and subsequently diverted.
How does diversion negatively affect my facility?
There are many ways diversion can have a negative impact on patient safety and facility liability. Below are some of the most common:
- Patients and staff members can be exposed to bloodborne pathogens.
- Impaired employees can be a danger to themselves, their colleagues, as well as patients.
- Poor facility reputation.
- Legal liability.
Litigation is very costly, as are fines imposed by the United States Drug Enforcement Administration (DEA) for lack of compliance with the federal requirements. Not too many years ago, the University of Michigan Hospital was fined $4.3 million dollars for violating provisions of the controlled substances act. Among their findings, the DEA noted that the hospital committed “recordkeeping violations, some of which included failing to maintain complete and accurate records of certain controlled substances that it received, sold, delivered or otherwise disposed of, and failing to notify DEA in a timely manner regarding certain instances of thefts or significant losses of controlled substances”.
How can I reduce the risk of diversion?
This is a discussion I commonly have with my clients. There is a long list of items you need to address to substantially reduce the risk of diversion. Below are just a few of the items your facility must address to reduce risk and liability:
- Expect diversion: If you haven’t encountered one yet, you are likely to do so. Don’t be complacent thinking it will never happen to you.
- Have a complete record of all movement of controlled substances within your facility.
- Require staff to sign off on receipt of medications.
- Secure all controlled substances at all times.
- Minimize waste. Wasting controlled substances provides many opportunities for diversion.
- Require witnessed destruction in real-time, every time.
How does working with a pharmacy consultant reduce risk and save money?
- Improved medication safety: Anytime we make our patients safer, we reduce the risk of harm and liability.
- Reduced labor cost: Diversions require a lot of time to investigate, report and resolve. When we pull people away from patient care to review potential diversions, labor costs go up. Good labor is not only hard to find, but also very expensive.
- Reduction in waste: Reducing waste not only saves on our medication spend, but it also reduces the opportunities for diversion.
- Improved detection: Having an expert audit your processes, enhances your ability to detect problems. The sooner you can resolve a potential issue, the more money you save.
- Regulatory compliance: Having efficient workflow that is fully compliant with state and federal requirements is not only a requirement, but it can also save you a lot of money by avoiding costly fines or litigation.
Drug diversion is an ongoing concern that puts patients at risk and is a huge liability for facilities. Having systems in place to mitigate these risks will help enhance patient safety and save your facility money.
We recommend you work with an expert pharmacy consultant to ensure you stay compliant. If you are not currently working with one or are working with one that is not expert in this area, contact us and we will assess your points of weakness and put in place processes that are fully compliant.
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.