Preventive Measures
Of course, any diversion strategy should address prevention. As Hearn noted, “Increasingly, the federal government is focusing on what healthcare organizations and pharmacies are doing to prevent diversion. Fines are a real possibility if you don’t have good policies and practices in place.”
Staff education and training are key components of prevention. Hearn said, “Make sure staff, including agency staff, are inserviced on appropriate documentation requirements. They need to understand they are responsible for those medications if a discrepancy is identified on their shift. Counting controlled substances at shift change not only ensures counts are correct, but also protects the nurse taking responsibility for those medications." This education and training, Hearn stressed, “is your first line of defense.”
Prevention is a team effort that starts with prescribers. They can practice caution when dealing with patients who frequently use or request opioids or other commonly diverted drugs. Working with the pharmacist and other team members, they should document completely and promptly when prescribing narcotics. They also should keep their DEA
or license number confidential unless disclosure is required, and they can eliminate or minimize the use of paper prescribing. Additionally, they can adhere to strict refill policies and make sure their staff know what to do if they suspect efforts to divert, steal or inappropriately access medications.
One important measure to ensure a consistent, unified team approach is establishing a Controlled Substance Diversion Prevention Program. This should involve various team members (including representatives from nursing, pharmacy, human resources, compliance and administration) and, deally, a dedicated diversion officer or, at least, someone with additional training or expertise in this area. This group could conduct regular diversion risk rounds to identify and address any issues or concerns.