into believing claims of pain were legitimate, because their practice ideas are dated, or because they are themselves dishonest and are aware their patients are diverting. Financial gain can motivate fraud on the part of a prescriber. For example, in August 2010, a New York physician was charged with leading a drug ring that allegedly provided oxycodone prescriptions to patients with no medical need, arranged to resell the drug to third parties, and distributed more than 11,000 pills resulting in a $1 million expense to the Medicaid program. 25 Certain signs should alert supervisors to the possibility that diversion may be occurring, for example: 91 ● Removing CS without a doctor’s order ● Removing CS for patients “not assigned” to them ● Removing CS for patients that have been discharged ● Removing CS and not documenting them ● Pulling excessive quantities of as-needed medication compared to other health care workers assigned to the patient ● Exhibiting discrepancies in inventory on a regular basis ● Pulling out CS in lower dosages to obtain more pills when the exact dosage is available ● Removing as-needed medications too frequently, for example pulling every 2 hours when the order is for every 4 hours ● Pulling out larger dosages of injectable medications to obtain more waste ● Experiencing continuing patient complaints of pain, despite documented administration of pain medications ● Falsifying records and failing to document waste Staff members who are engaging in diversion within a facility such as a hospital may often volunteer to witness or administer CS, have major life changes or injuries, frequently disappear from the floor, or have periods of high and low productivity not consistent with colleagues.
Staff members other than HCPs may also divert medications. Support staff employees who may be diverting CS may be spotted in areas where they are not unauthorized, may unnecessarily touch syringes, may stay late when their services are unnecessary, and may always volunteer to help dispose of waste. 91 If either HCPs or support staff are impaired, they may appear sleepy, exhibit personality changes, commit multiple errors or be unable to perform routine tasks, take excessive sick leave or extended breaks, and be the target of multiple patient complaints. 91 To effectively combat diversion, cooperation is necessary across multiple teams and facility divisions. The Mayo Clinic has laid out the following set of recommended steps when diversion in the workplace is suspected or identified: 90 ● Secure whatever evidence is available ● Initiate drug testing ● Initiate a discussion with the employee’s supervisor ● Review of any records documenting handling of CS ● Institute additional surveillance if necessary ● Initiate recurring meetings of a drug diversion response team to review findings ● Quickly remove from patient care any employee found to have diverted CS ● Quickly close the case of any employee determined not to have diverted CS ● Report findings to the DEA, the state pharmacy board, and local law enforcement More possibilities include urine drug screening and agreement to comply with diversion prevention policies prior to hiring in addition to ongoing random or “for cause” testing. Newly hired facility workers should receive education to prevent diversion, and that education should be ongoing. Mandatory reporting procedures and methods of surveillance, including checks of prescribing records and video surveillance, should be in place. It is important to check relevant laws in the state of practice as some states require that diversion of CS be reported to federal authorities and result in loss of license to practice medicine. After taking some time to absorb the signs of diversion within a healthcare facility, read over the case example that follows and consider what steps should be taken.
Book Code: TN24CME
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