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reimbursement rates and potential penalties for substandard patient care, CMS may revoke a facility’s participation in Medicare due to CoP violations.
The FDA and Environmental Protection Agency (EPA) also have rules in place for proper disposal of controlled pharmaceutical sub- stances, and further hold facilities and providers nancially liable when rules are not followed.11
Guidance and Tools
Given the breadth of drug diversion in healthcare settings, the American Society of Hospital Pharmacists (ASHP) published guidance on preventing diversion of controlled substances in October 2016. ASHP guidelines include legal and regu- latory requirements and special considerations, as well as an ap- pendix guide to self-assess existing programs and remedy potential liabilities.12
CMS offers an online drug diver- sion toolkit (available at cms.gov), which includes multiple information- al booklets, self-audit tools and edu- cational resources, for Medicare and Medicaid providers. Those unfamil-
iar with drug diversion may bene t by rst reading the Prescription Drug Diversion Resource Guide. The Guide offers the types of prescription drugs most susceptible to drug diversion and speci c behaviors attributed to drug diverters.13
The Institute for Safe Medication Practices (ISMP) offers safe practice recommendations for nurses (spe- ci cally, traveling nurses), which includes a checklist that educates nurses on the behavior and physical signs of diversion, as well as steps
to take against diversions that may occur in their presence.14
Full text of the Mayo Clinic’s
Diversion of Drugs Within Health Care Facilities, a Multiple-Victim Crime: Patterns of Diversion, Scope, Consequences, Detection and Prevention, is available at mayo- clinicproceedings.org.
Consultants who specialize in reducing drug diversion are also
available to help facilities and provid- ers ensure appropriate policies and procedures are in place.
Albeit caused by a few, an unfath- omable amount of drug diversion occurs throughout U.S. healthcare facilities and pharmacies. Avoiding issues of diversion does not render immunity from prosecution — fed- eral and state laws make everyone complicit. Pharmacy directors and pharmacists are especially vulnerable due to the responsibilities of their position. In addition to facing nan- cial penalties, pharmacists may lose their license.
Comprehensive procedures to address drug diversion are vital to patient health and safety, as well as the health and safety of healthcare providers and facilities. Continuous collaboration, education and over- sight may encourage an addict to seek treatment for the devestating disease.
Sources
1U.S. Department of Health and Human Services/CDC, Drugs Most Frequently Involved in Drug Overdose Deaths: United States, 2010–2014, December 20, 2016, accessed February 2017 at cdc.gov
2Wolters Kluwer Health: Lippincott Williams and Wilkins, Costs of US prescription opioid epidemic estimated at $78.5 billion, September 14, 2016, accessed February 2017 at sciencedaily.com
3Kurt Eichenwald, When Drug Addicts Work in Hospitals, No One is Safe, June 18, 2015, accessed February 2017 at newsweek.com
4Christopher N. Osher and David Olinger, Drug addicted, dangerous and licensed for the operating room, June 2, 2016, accessed February 2017 at denverpost.com
5Holly Zachariah, Employees stealing drugs from Ohio pharmacies, healthcare facilities, updated April 17, 2016, accessed February 2017 at dispatch.com
6Mark Lowery, Court: Pharmacist responsible for pharm tech’s massive theft, September 25, 2015, accessed February 2017 at drugtopics.modernmedicine.com
7Beatric Dupuy, Drug thefts turn up big in state report on abuse and neglect of vulnerable Minnesotans, December 28, 2015, accessed February 2017 at startribune.com
8Kimberly New, JD, BSN, RN, Detecting and Responding to Drug Diversion, June 30, 2015, accessed February 2017 at rxdiversion.com
9Cheryl Clark, 10 Ways to Halt Drug Diversion by Healthcare Workers, September 2, 2016, accessed February 2017 at healthleadersmedia.com
10Center for Disease Control and Prevention, Risks of Healthcare-associated Infection from Drug Diversion, updated August 30, 2016, accessed February 2017 at cdc.gov
11Hospital Safety Center (extracted from Kimberly New, BSN, JD, Drug Diversion in Healthcare), Drug Diversion: Regulatory requirements and best practices, December 29, 2016, accessed February 2017 at hospitalsafetycenter.com 12ASHP, ASHP Guidelines on Preventing Diversion of Controlled Substances, 2016, accessed February 2017 at CS-Guidelines-Prepress.pdf
13CMS, Program Integrity: Drug Diversion Toolkit, updated 2016, accessed February 2017 at CMS.gov
14ISMP/Nurse AdviseERR, Partially lled vials and syringes in sharps containers are a key source of drugs for diversion, April 2016, accessed February 2017 at pprtravelnursing.com
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