Drug diversion didn’t disappear when COVID-19 hit. Many changes associated with managing the COVID-19 pandemic in hospitals may be creating new opportunities for drug diversion by increasing both access and opportunities for diversion. Consider that the U.S. Department of Justice is busy investigating violations of the Controlled Substance Act, and recently two large health systems negotiated significant financial penalties – one being $4.5 million for failure to “guard against the theft and diversion of controlled substances.”
However, proactive surveillance and a well-established diversion management plan can help organizations avoid significant patient safety, reputational and financial risks. Foundationally, the diversion program is no longer the responsibility of just the pharmacy department. Diversion is first and foremost a patient safety problem that may only be solved by an interdisciplinary approach.
For 2022, hospitals and health systems will need to focus on:
- Diversion Program Structure – A governance committee chaired by leaders, including the DEA registrant, is a must. The governance committee supports the work of the diversion program, ensuring that there are adequate, dedicated resources for diversion surveillance, investigation, and event management. Additionally, the governance committee facilitates the intra-departmental efforts to prevent diversion by ensuring cooperation across any departments involved in the handling of controlled substances; from IT to Waste Stream every department has a role.
- Dedicated Diversion Resources – diversion prevention, surveillance, detection and event management require specific skills, talent and subject matter expertise. Spreading the tasks of diversion detection across myriad managers and staff in multiple departments will not result in improved detection. Ask yourself how many diverters were caught in 2021? If the answer is none or only a few, then your program is ineffective or non-existent. Effective programs are led by a dedicated Diversion Specialist with a team of analysts who can efficiently and effectively manage your diversion analytics, coordinate the activities of the Diversion Response Team, and determine the root causes and solutions when diversion occurs. Diversion programs more and more are moving out of the pharmacy and into a “neutral” department to avoid the inherent biases caused by supervisory relationships.
- Diversion Analytics – Diversion detection depends on surveillance analytics that enables you to see the red flags when diversion occurs. Several good software systems are commercially available, so make this a goal for 2022 to invest in a system that matches the goals of your diversion program.
- Diversion Playbook – don’t wait for the next diversion to start to plan how to manage the event. Diversion will occur, so pull together your Diversion Response Team and make a plan that covers how to investigate, interview, and intercede on behalf of the individual. Define the role of Local Law Enforcement, the role of Human Relations, reporting to professional licensing boards, and how your organization will support an individual with substance use disorder who has also committed a crime.
Pharmacy leaders should not shoulder the full weight of the drug diversion program nor should the pharmacy budget absorb the full cost of the program. Leverage your relationships and guide the organization towards fully supporting a comprehensive, multidisciplinary diversion program that mitigates the risk of patient harm, reputational damage, and financial loss.