Drug Diversion Prevention: Compliance Strategies to Mitigate Risk

The opioid crisis and hospital drug theft have been appearing more frequently in headlines for several years, making drug diversion a front-running issue in the acute space. In 2018, the Department of Health and Human Services Office of Inspector General and state and federal law enforcement partners participated in the largest health care fraud takedown in history. According to graph below by the United States Department of Justice, more than 600 defendants were charged with participating in fraud schemes involving about $2 billion in losses to Medicare and Medicaid[1].

Data shows that drug diversion is an issue that’s very much alive. As a result, hospital drug diversion prevention has been a focus for many compliance departments, with efforts ranging from screening employees, limiting access, and increasing audits and overall security. Drug diversion in the healthcare space can pose major health and safety concerns for patients and care workers alike. Health systems are faced with the challenge of tackling drug diversion to help ensure patient safety and assimilate help for care workers who struggle with addiction. There are steps health systems can implement for a full-lifecycle drug diversion monitoring program that drives diversion out of their facilities and creates a culture of privacy, security, and compliance.

Best Practices for Hospital Drug Diversion Prevention

At a high level, facilities must take a multi-layered approach to a drug diversion prevention strategy. Healthcare privacy, security, and compliance professionals must align to conduct internal audits that search for signs of drug diversion and identify the who, what, when, and how of drug diversion in their facility. Additionally, enhancing hospital policy and procedures and training employees will help drive a culture of compliance that reduces and prevents future incidents.

At a more granular level, a facility’s medication-use process (MUP; e.g., procurement, storage, preparation, prescription, dispensing, administration, waste, return, and removal) has multiple vulnerabilities that can be exploited and must be complimented with comprehensive drug diversion policies. The table below outlines the stages of medication-use processes and the safeguard policies they can implement when creating a comprehensive diversion program.

Mitigate Risk through Compliance

The presence of a strong drug diversion program is the most effective method in reducing and preventing drug diversion cases at a hospital. To help prevent drug diversion, it is recommended to have an aggressive audit process in place to help identify drug diversion. It has been found that the simple fact of knowing that you are being monitored on a regular basis increases compliance and minimizes opportunities for diversion. With a solid medication monitoring program supported by a committed drug diversion program, early detection can prevent putting patient safety at risk.

One of the biggest barriers to stopping drug diversion is having proper reporting tools implemented and used at hospitals. Facilities need to have compliance policies and procedures in place to review, track and trend drug dispensing data, validate drug use through patients’ charts, and investigate any variances in data of drug utilization by nurse, condition, physician, patient, etc. Additionally, drug waste disposal procedures should be monitored by the pharmacy and need to be strictly adhered to, immediately reporting any incidents that do not comply.

[1] https://www.justice.gov/opa/documents-and-resources-june-28-2018