To fully address drug diversion in healthcare, you need a full-lifecycle drug diversion program that considers the patient, the care provider, and the drug diverter themselves. An effective drug diversion monitoring and remediation program will include cross-department collaboration, comprehensive internal and external reporting procedures, proactive monitoring, and training to help foster a culture of privacy, compliance, and security in your organization. In doing so, you can help ensure proper patient care, help care workers struggling with addiction, and prevent your facility from suffering the consequences of drug diversion.
Below are nine quotes from the webinar “Addressing Drug Diversion in Healthcare: Where Do I Start?” by Commander John Burke, President of Pharmaceutical Diversion Education and Trent Long, Director of Managed Privacy Services at FairWarning to help you craft or further develop your drug diversion program.
Quote #1: “Schedule II drugs are often being diverted most.” Commander John Burke, President of Pharmaceutical Diversion Education
High-value Schedule II-V controlled substances are the most commonly diverted drugs. According the U.S. Bureau of Labor Statistics, of the top 17 abused prescriptions, 94% were classified as Schedule II, III, or IV medications including Ritalin, Oxycodone, Ativan, Vicodin, and Percocet. Drug Enforcement Administration (DEA) rescheduled hydrocodone combination products from Schedule III to Schedule II. Prior to this, hydrocodone combination products could be refilled as much as 5 times in a 6-month period – this is in an attempt to make it more difficult to abuse this particular medication.
Quote #2: “There are very few instances where drug diversion is made for financial gain. In the vast majority of cases, it’s addicts feeding their own addiction.” Commander John Burke, President of Pharmaceutical Diversion Education
According to a 2017 study, up to 15 percent of healthcare workers are addicted to drugs or alcohol, compared with 8 percent of the general population. The highly addictive nature of drugs coupled with healthcare workers’ easy availability to controlled substances makes them especially vulnerable to addiction. And while there have been cases of drug diversion that involve reselling the drugs for profit, most of the cases identified are driven by the diverter’s addiction.
Quote #3 “The diversion of drugs from health facilities is still vastly underreported.” Commander John Burke, President of Pharmaceutical Diversion Education
Whether out of fear of adverse consequences or a simple misunderstanding of proper reporting procedures, there is evidence that drug diversion is being vastly under reported. John Burke, extrapolated data from healthcare facilities in Ohio – the outcome was an estimate 37,000 drug diverters per year- yet only 300 cases are reported. But the consequences of not reporting can be serious for the patient, the care provider, and the drug diverter themselves. If a suspected diverter is removed from their job but not reported, they could become a repeat offender, moving freely from job to job without evidence documenting their past activities. Care providers will suffer costly repercussions for not reporting, like the 10 healthcare providers that were fined in the Kwiatkowski case.
Quote #4: “HR is the gatekeeper of your facility.” Commander John Burke, President of Pharmaceutical Diversion Education
Human resources (HR) plays an important role in a drug diversion monitoring program, informing compliance of any issues related to drug diversion. After a fully documented investigation, HR will determine the best course of action for each instance. This involves documenting processes, collecting immutable evidence, confronting drug diverters, and coordinating treatment programs for diverters.
Quote #5: “You can train your staff to identify addicts to help foster a culture of security and compliance.” Trent Long, Director of Managed Privacy Services, at FairWarning
Your staff are your best set of eyes and ears in your organization, and drug abusers typically exhibit recognizable but often subtle symptoms of addiction. Leverage that visibility by fostering an awareness in your staff of the issue of drug diversion and how to spot care workers who are struggling with addiction. The DEA suggests that you train your team to recognize impaired co-workers. The DEA lists such possible signs as more shifts worked than usual, heavy PRN, excessive amounts of time spent near a drug supply, declining work performance, and patient and staff complaints.
Quote #6 “Creating an anonymous reporting ability for your staff is a powerful tool to reduce fear of reporting and help addicts reach out for help.” Commander John Burke, President of Pharmaceutical Diversion Education
Care workers may be hesitant to report instances of drug diversion that they witness out of fear of stigma, or of causing harm to their coworkers, who may also be their friends or family. Creating an anonymous reporting program is an essential part of your drug diversion monitoring program that will allow you to formulate a database that standardizes the reported information. Furthermore, you should make it clear that any employee may reach out for help with their addiction – doing so has proven to be a successful way to do so to reduce shame and fear.
Quote #7 “Hiring a drug diversion specialist will help strengthen your program; the best drug diversion specialists are usually from nursing or pharmacy.” Commander John Burke, President of Pharmaceutical Diversion Education
You should consider hiring a drug diversion investigator (DI) to deter diversion in your facility. DIs handle a wide range of duties around the proper handling of controlled substances and scour your systems’ audit logs and monitoring platforms to spot for unusual behavior. They often also serve as the head of a diversion committee. The DI serves an important role in your investigations as a liaison between the DEA, legal, law enforcement, and compliance. Consider hiring a specialist with a background in nursing and pharmacy – their experience and expertise may help them identify and investigate instances more efficiently and accurately than those without experience in these areas.
Quote #8: “You should confront the addict with evidence and empathy and identify possible treatment options with HR or with the nursing board.” Commander John Burke, President of Pharmaceutical Diversion Education
Remember that many drug diversion cases are driven by addiction rather than financial gain. Addiction has hefty consequences for the drug diverter themselves, including health issues, family and personal problems, job loss, and a criminal record. By confronting the addict with evidence and empathy, you can help create a path for treating, rather than criminalizing or punishing, the addicted care worker. This process usually starts with HR, and may also involve the nursing or physicians board.
Quote #9: “Using your Patient Privacy Intelligence platform in conjunction with monitoring dispensing systems, such as Pyxis and Omnicell, can help detect drug diversion.” Trent Long, Director of Managed Privacy Services, at FairWarning
The key element in a drug diversion program is the monitoring of user activity in your EHRs and pharmacy dispensing systems. A platform like Patient Privacy Intelligence (PPI) can allow you to track and trend user behavior across all systems – including HR systems for identity correlation and other clinical applications to detect patterns of behavior – giving you immutable evidence to present in your investigation.
FairWarning has developed a machine learning model based on known drug diversion cases at customers’ facilities. By running this model over the behavior of users in your EHRs, clinical applications, and dispensing systems, platforms like FairWarning can help customers detect and remediate drug diversion for a full lifecycle program with complete visibility across the organization.