Drug Diversion Detection and prevention advice BY ROBERT KURTZ


rug diversion and poor manage- ment of controlled substances in

a health care facility can lead to seri- ous consequences. This illegal trans- fer and use of prescription medicines could result in patient harm and fines and loss of license for an ASC. Preventing drug diversion begins with understanding the laws relating to the control and diversion of drugs, says Pamela Dembski Hart, principal of Plymouth, Massachusetts-based Healthcare Accreditation Resources LLC, a provider of health care accredi- tation, safety and compliance consult- ing services. “If you follow the Drug Enforce-

ment Administration’s (DEA) require- ments, that is the first crucial step to help prevent drug diversion,” she says. The DEA’s Controlled


Security Manual can be found at manuals/sec/app_law.htm. It is critical for ASC leadership to

provide staff with education on drug diversion, says Aimee Mingus, direc- tor of clinical operations for West- chester, Illinois-based ASC man- agement and development company Regent Surgical Health. “It needs to be an annual education piece during which the ASC’s policies are reviewed and the impact diversion can have on patients, employees and the ASC as a whole is discussed. “You also want to use this time to

establish a blameless culture around drug diversion,” she advises. “Staff members need to feel comfortable about speaking up if they suspect drug diversion may be occurring and should know they will not face repercussions if an investigation proves otherwise.” Dembski Hart adds that staff mem- bers should realize they have a per- sonal and fiduciary responsibility to protect patients. “The resulting conse-


quence of not reporting far outweighs the denial or resistance from the gov- erning board or management that a problem exits,” she warns. While following the laws will help

provide protection against drug diver- sion, ASCs can take other steps to strengthen their safeguards, Dembski Hart says. “It is imperative that ASCs maintain strict logs on their controlled substances, and that those logs are easy to use and understand. There are many different types of logs an ASC can pur- chase, but many will not be suited for the outpatient setting. ASCs should find a solution that meets their specific needs as sloppy record-keeping will make theft easier and detection more difficult.” It is imperative for ASCs to ensure

staff follow policies dictating how medications are handled, Mingus says. “There should be at least two peo- ple responsible, and someone should be tasked with oversight of those staff members. A system needs to be in place

where someone is periodically check- ing to make sure policies are working.” That individual could be an ASC’s

consulting pharmacist, she says. “There are fantastic consulting pharmacists who take the time to track the entire path of medications given to patients to ensure they were handled and delivered appropriately. ASCs should make sure they have a pharmacist who is diligent about checking policies.” Dembski Hart advises ASC lead-

ers to watch for abnormal behavior that could indicate a staff member is trying to access medications. “If someone is frequently coming into work on their days off or giving rea- sons why they need to stop by, those may be warning signs. “The person who is stealing the

drugs often works hard to put them- selves close to the medications. They might volunteer all of the time to get the medicines. Such repeated actions may warrant investigation,” Mingus says.

Staff members need to feel comfortable about speaking up if they suspect drug diversion may be occurring and should know they will not face repercussions if an investigation proves otherwise.”

—Aimee Mingus, Regent Surgical Health

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