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As healthcare systems get better at creating barriers, thefts that occur will be closer and closer to patient care.
Federal agencies, including the Department of Justice (DOJ) and the DEA, which licenses practitioners for distribution of controlled sub- stances, are collectively ramping up efforts to curtail drug diversion by prosecuting healthcare professionals and leveling nes against healthcare facilities and providers who violate the Controlled Substance Act (CSA). A federal law, CSA requires hospitals to le a report (DEA-106, available at deadiversion.usdoj.gov) to the DEA for any “theft or signi cant loss” of controlled substances upon discov- ery of “discrepancies.”
The Centers for Medicare & Medicaid Services (CMS) is partner- ing with the DEA’s Of ce of Diversion Control to prevent, detect and inves- tigate drug diversion of pharmaceu- ticals and listed chemicals, which are used as ingredients for street drugs. Medicare conditions of participation (CoP) mandate multiple processes related to patient safety and the se- curity, handling and recordkeeping of controlled substances be in place. Records, for example, must include all controlled substance movement throughout a facility (beyond procure- ment and inventory) and be readily retrievable. In addition to impacting
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