When establishing a diversion monitoring program, it is critical to educate your organization’s senior leadership on the risks posed by drug diversion and the need to build a strong cross-departmental team to tackle this problem. Valuable resources that can support your approach include high-level editorials, ROI analyses, or authoritative guidance from such organizations like ASHP on the importance of such programs.
However, the key element to establishing executive buy-in is to figure out what “wins” your organization currently prioritizes. While different organizations may have different incentives for enhancing diversion monitoring, there are often five key incentives including:
- Workforce efficiency
- Avoiding reputational risk
- Patient safety
- Workforce safety
- Avoiding regulatory risk
1. Workforce efficiency and (2.) avoiding reputational risk
Diversion events tend to make the local - and sometimes national - news. Health system reputations and success are built on a foundation of trust within the communities they serve, and diversion can disrupt that trust and put lifetime patient value at risk.
Often times, having a proactive program can prevent catastrophic diversion incidents from happening. Overall, more cases will usually be discovered, but it will happen at a point in which damage can be prevented or largely mitigated. These events will typically not receive the level of media coverage more complacent institutions that would rather take the attitude that it doesn’t happen in their facility.
3. Patient Safety
Patients can be put at significant risk with diversion in a variety of ways. Examples include patients not receiving necessary drugs, having IV medications or fluids infused that have been contaminated with bloodborne pathogens, or having patients treated by individuals who are impaired due to controlled substance abuse. Any organization with a focus on patient safety must have a specific focus on preventing controlled substance (CS) diversion. Failure to do so will put patients at risk, damage the reputation of the institution, and possibly even threaten its future business viability
4. Workforce Safety
A major concern of many health systems relates to the occupational health risks associated with working with individuals who may be diverting, and are impaired at the workplace as a consequence. The inability to trust your colleagues puts all employees at risk and damages overall workforce cohesion. Also, workforce members can be put in an uncomfortable position if the only current means of detecting diverters lies with them reporting their own observations.
Many employees and managers would rather rely on more advanced surveillance methods. This also helps to avoid a scenario in which employees may be providing conflicting information.
5. Avoiding Regulatory Risk
It is undeniable that regulatory risks and fines are getting more aggressive when it comes to controlled substance diversion, and patterns of enforcement. A notable $2.3M fine was levied in 2015, and since then, there have been additional fines of $4.1M and $4.3M levied in 2018.
The Drug Enforcement Administration (DEA) is primarily responsible for these levies, though in cases of wide-scale fraud, the FDA, the OIG, and many other agencies may become involved. It is important to note that DEA Diversion has become more interested in health facility diversion over the past few years as they have become increasingly aware of the complacency of some in the industry. This scenario makes it even more important that the facility does all it can to comply with federal and state regulations and to develop a proactive drug diversion program that keeps diversion to a minimum.
Throughout the Controlled Substance Diversion Monitoring Playbook handbook, proper steps and protocols essential to a drug diversion program are explored. By systematically approaching each of these topics, health systems are able to establish the proper environment for Controlled Substance (CS) diversion monitoring and prevention.
Download the full Controlled Substance Diversion Monitoring Playbook to view a centralized and practical resource for healthcare organizations that are either starting, in the midst of creating or optimizing their current drug diversion monitoring and resolution programs.
