Drug diversion is a challenging and pervasive problem facing healthcare facilities. It can be extremely hard to come to terms with the fact that someone we work with could be diverting drugs for their own use. However, the United States Drug Enforcement Administration (DEA) has repeatedly shown that ignorance is not an option, and that if one of our colleagues is found to cause harm by their diversion, then the facility can be held accountable. Getting started with a drug diversion program is the hardest part, and in the article, we will show you the simplest way to begin.
Drug diversion process
The first thing to know is that a well ordered and documented process is essential for monitoring drug diversion. It does not have to be complicated but it does have to be reliable. Drug diversion is a complex problem occurring in a busy and high-pressure work environment. There is also a significant psychological stress on staff members who may be unsure of what or how to report potentially suspicious activity. A good process will take all the guess work away and remove all of the pressure from your staff to report suspicious activity. The process becomes a habit, it is emotionless, and you simply log datapoints that can be reviewed periodically for unusual patterns.
Implementing a reliable process that is easy to adopt for everyone at your facility has a huge benefit. Namely, it will help stop drug diversion. This means that patients will not be at risk, and you will not face strict sanctions and lawsuits from the federal government or affected families.
What should your staff report
A reliable drug diversion monitoring process involves the reporting and logging of any anomalous activity. Notice the use of the word anomalous and not “suspicious”. Suspicion requires the person reporting on the activity to make a judgement, was what they saw, ok or not? This is not the purpose of monitoring. The purpose is to gather data points, most of which will not be remotely suspicious on their own. It is only when the information is recorded and logged that suspicious patterns begin to emerge.
So what should people report?
The answer is really anything out of the ordinary. Damage to equipment, missing doses, damaged labels. It should become habit for people working with you to report things that don’t seem right, however small and trivial they may seem.
It’s also important to consider how people report their observations. Do you have regular meetings where you can remind people to report anything they have seen? Would it be better to have an anonymous reporting system where staff can anonymously submit what they see? This depends on your current communications systems and any reporting mechanism must work seamlessly with what is already in place.
How to start record keeping
At the beginning of your monitoring program, it doesn’t make sense to have an elaborate or complicated record keeping system. In many cases, a simple spreadsheet will suffice. Here you can record the date and time as well as a brief description of the anomalous activity. At some point, you will hopefully outgrow this as reporting becomes more frequent and you can implement automated solutions and software to help handle it. However, at the beginning, you simply need a single point of information where you can manually check for unusual patterns that could be signs of drug diversion.
What are the tell-tale signs of drug diversion?
While drug diversion can be difficult to identify, there are some indicators that would immediately raise suspicion. If a number of these were detected in your records, then there is a high chance that drug diversion is happening, and an investigation should be launched.
Reporting inconsistencies
If you notice that drug doses are being recorded differently on different forms, this could be caused by human error, however if it becomes a pattern, it could be caused by someone deliberately manipulating reports to hide diversion.
Damaged or tampered packaging
Packaging can become damaged for any number of reasons. However, if it keeps happening it could also be a sign of drug diversion. Look out for;
- Vials that are missing caps
- Containers that are not completely full
- Sticker labels being removed or damaged
- Needle marks in rubber vial stoppers
- Reattached vial caps
- Any restricted medication with a broken seal
Unusual requests
Unusual requests are fine, as long as they are infrequent and there is no pattern associated with them. Be on the lookout for higher doses than normal or higher frequencies. There may be legitimate reasons, but this is also a hallmark of drug diversion where people request higher doses than they need in order to keep the unused dose for themselves.
Ineffective pain relief
Are patients complaining that pain relief is not effective? As with everything that has already been mentioned, this is not unusual in isolation when it occurs rarely. However, is a pattern in your record emerging of several patients complaining about ineffective pain relief dosing? Drug diversion could be the answer.
Drug-items found in bathrooms and breakrooms
A drug label or vial in the breakroom trash may seem innocent enough, but if your records begin to show that this is a pattern, then there may be a more serious problem.
Behaviors
Unusual behavior in staff can be a sign that something is wrong. It is important to report any inconsistencies that may arise from incorrect dosing or unusual drug wasting activity. It is worth monitoring the rooms of patients who are receiving controlled substances to see if people visit them regularly who may not need to.
Investing in quality assurance
Quality is so important when it comes to patient care and administering prescription drugs. This article has focused on drug diversion because it is such a pervasive and dangerous problem. However, many of the tell-tale signs, could be caused by other factors. For example, if a patient is complaining about ineffective pain relief, it could be that someone is accidentally administering the wrong dose and requires more supervision or training. Even though this particular case may not be directly related to drug diversion, an effective drug diversion monitoring program would help you detect it. This means that your program is not just a way to prevent dangerous and costly drug diversion activities, but also a way to generally increase the quality of care to patients.
Continually review your records
Once you have established your program, it is important to regularly review the records that are being collected. This goes for your own documentation, but also reviewing with staff members how and what they report to you as anomalous. It can seem like a lot of additional work, and this is a problem, because it decreases the likelihood that it will get done. This is why your program should start of simple and should be embedded in routine activities.
For more information visit the IHFDA’s website and find out “How diversion affects all of us” or meet us at the IHFDA 5th Annual Conference in September.
