Posted on June 15, 2018 in: Patient Safety
By Brian D. De Smet, Pharm.D., M.S., pharmacy specialist, Henry Ford Hospital, Detroit
“Diversion,” as defined in the Uniform Controlled Substances Act of 1994, means the transfer of a controlled substance from a lawful to an unlawful channel of distribution or use and should always be an issue of concern to pharmacists and pharmacy staff.
As the last checkpoint before hitting the public, preventing diversion is just as important to the general safety of public health as dispensing the appropriate medication for a patient. It is for that reason we have legal, electronic and manual safeguards in place.
Controlled substance abuse has become an important public health issue in many countries since 2010, especially in the United States. Consider in 2016 in the United States:
Just over one year ago, the former Secretary of U.S. Health and Human Services (HHS) Department outlined five major priorities that HHS would be focusing its efforts on:
The current Secretary of HHS has embraced these priorities and has continued with grant awards to all 50 states, four U.S. territories and the free associated states of Palau and Micronesia, totaling $485 million to continue the efforts of the United States to combat the opioid crisis.3
All healthcare facilities should have systems in place to deter controlled substance diversion that include methods to promptly identify and investigate possible diversion, intervention when it is occurring and follow up to deal with outcomes of confirmed diversion.
The first layer in the foundation of a diversion deterrence program is having written and enforceable policies to prevent, detect and properly report diversion. Although pharmacy is the main target of such policies, they should ideally come from a multidisciplinary committee to ensure “buy-in” from all players on the program structure and any associated expenses that will be incurred. An extension of these policies should also include instructional and outreach activities for employees throughout the system, not just those with direct access to the medications. Broadening awareness to the issue adds more eyes on the lookout for nefarious activities.
Next, procedures for observing processes defined in the policies, and for auditing drug transaction data for diversion, must be defined and followed. While no technology is entirely foolproof, automated tracking devices and software such as dispensing cabinets, barcode scanning and radio frequency identifiers (RFID) transmitters and receivers, allow for instant auditing of drug transaction data for not only controlled substances but also for any product that would benefit from the same surveillance, notably high cost medications or those with short expiration dates. The pharmacy profession has always been near the forefront when it comes to adopting new technologies to make our profession more efficient and our actions safer for patients. It is an easy assumption that most, if not all, hospitals across the country have made capital investments in hardware and software to make the process of automated tracking possible. The key would be incorporating this appropriately into the program’s policies.
Third, the program must address suspicious activities and audit results in an expedited manner. This is important not only to minimize the amount of diverted material but to also gather evidence for your facility’s Human Resources department or in the event a criminal prosecution becomes necessary. While we try to maintain a non-punitive environment as much as possible, certain specific actions or culmination of incidents may require follow-up with law enforcement, regulatory officials and/or public health bureaus.
Regardless of what specific technology and personnel are afforded toward preventing drug diversion, it is crucial to have a proper foundation of policies, procedures, education, technology and accountability in order to minimize the risk to your institution.