Drug Diversion Prevention in Healthcare

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Drug Diversion Prevention in Healthcare

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Drug Diversion Prevention in Healthcare

Kimberly New, BSN, JD

Theft of controlled substances at hospitals has always been a problem of paramount importance, but even with increased security measures, it still occurs. Drug Diversion Prevention in Healthcare discusses the issue of drug diversion in detail and demonstrates the components of a solid prevention plan. Loaded with tools and checklists, this book is designed to help hospital security officials create awareness of the drug diversion problem. You will learn how to design a program to keep staff accountable for drug administrations, as well as audits that monitor drug distribution from delivery to patient administration.

This resource will help you: 

  • Establish an effective drug diversion prevention plan among hospital staff 
  • Understand the fundamental issues of drug diversion 
  • Create awareness among staff using tools and checklists 
  • Learn to recognize suspected diverters and mitigate problem areas in your hospital 
  • Effectively confront and deal with diverters in your facility 

About the Author:

Kimberly New, BSN, JD, is a consultant to healthcare institutions on the subject of drug security and diversion. She is the founder and principal consultant of Diversion Specialists, a firm that specializes in preventing, detecting, and responding to drug diversion by healthcare personnel. New is a nurse and an attorney, with extensive clinical experience as a nurse as well as many years of experience as a healthcare lawyer. She has also worked as a compliance officer at both a large long-term care company and an academic medical center.

Published: November 2016

Page Count: 150

Dimensions: 8.5 X 11
ISBN: 978-1-55645-937-5

Table of Contents

Chapter 1: Introduction to Drug Diversion

Scope of the Problem
Risks Associated With Diversion
Regulatory Requirements and Considerations

Chapter 2: Establishing a Prevention Program

Diversion Oversight Committees

Nursing and Pharmacy
Risk Management and Quality
Chief Medical Officer
Infection Prevention
Human Resources and Employee Health
Ad-Hoc Members

Diversion Response Teams
Diversion Specialists
Gaining Buy-In to the Program
Developing a Systemwide Approach

Chapter 3: Regulatory Requirements and Best Practices

Patient Safety
Patient Privacy
Security and Medication Handling Requirements
Diversion Investigation and Response
CEO and Board Communication

Chapter 4: Staff Education

Pharmacy Staff
Charge Nurses and Team Leaders
Physicians and Midlevel Provider Staff

Chapter 5: Diversion Risk Rounds

Risk Rounds in the Pharmacy
Risk Rounds in Nursing Units
Risk Rounds in Operative and Procedural Areas
Risk Rounds in Medical Offices

Chapter 6: Surveillance and Physical Security

Video Surveillance
Badges and Electronic Measures
Transportation Security
Access Restriction
Drug Cabinets

Chapter 7: Patterns of Drug Diversion

Commonly Diverted Drugs
Identifying and Managing Noncompliance
The Problem of “Pre-Pulling”
Travelers and Agency Workers

Chapter 8: Special Considerations


Stocking and Reprocessing Return Bins
Closing the Loop
Waste and Reverse Distribution
Controlled Substance Overrides
Patient-Specific Controlled Substances
Specialized Monitoring
Controlled Substances for EMS Providers
Outpatient Pharmacy Considerations

Physician Office Practices
Prescription Control

Prescription pads

PCA and Controlled Substance Drips
Labor and Delivery
Anesthesia, Surgery, and Procedural Areas
OR Pharmacy

Chapter 9: When to Suspect Diversion

Characteristics of a Diverter
Patterns of Diversion
Automated Drug Cabinet Reports

Chapter 10: Methods of Diversion

Diversion by Falsified Records
Tampering and Substitution
Best Practices are the Best Prevention
Waste in the Pharmacy
Regulatory Matters Related to Waste
Assessing Controlled Waste Practices for Diversion Risk

Chapter 11: Investigation of Suspected Diversion

Establishing Reasonable Suspicion and Protecting Patients
Interviewing Suspected Diverters
Drug Testing

Chapter 12: Response to Confirmed Diversion

Internal Reporting
External Reporting
Prosecution and Public Notification
Patient Privacy Considerations
Root-Cause Analysis
Barriers to Diversion Response


Appendix A: Basic Auditing Components Outline
Appendix B: Recognizing Drug Diversion in Healthcare Facilities
Appendix C: Consent to Draw Blood for HIV, HBV, and HCV Infectivity Testing
Appendix D: Sample Diversion Oversight Committee Charter
Appendix E: Diversion Program Structure
Appendix F: Diversion Risk Rounds Checklist
Appendix G: Sample Diversion Specialist Job Description