Establishing a Controlled Substance Proactive Diversion Program
Establishing a Controlled Substance Proactive Diversion Program Russell Dorsey, CPhT Special Projects/Indigent Care Program Coordinator Baptist Health Medical Center Little Rock Disclosure I have no financial interests or other disclosures of conflict of interests for this presentation. Pharmacist Objectives Outline controlled substance diversion
Summarize a proactive diversion program Implement proactive diversion procedures Technician Objectives Define controlled substance diversion Outline the organization of a proactive diversion
program Explore the ways to implement proactive diversion procedures What is diversion and what does it mean to my organization? Transfer of medication from a lawful to unlawful channel of distribution or use Patient Safety
Patient/Community Perspective Liability & Fines Question? What is the estimated rate of nursing staff with substance use disorder? 1) 2% 2)
5% 3) 10% 4) 15% Outline CS Diversion Drug Theft
Personal Use Sale Use by family or friend Tampering Doctor Shopping
Illicit practices by health care providers Forging Prescriptions Drug Theft Medical Staff Drug Theft Patients/Visitors Tampering Doctor Shopping
Illicit practices by health care providers Summary of Proactive Diversion Program Collaboration Data Analysis Identification
Reporting Process Improvement Education Implement Proactive Diversion Procedures Multidisciplinary Diversion Response and Prevention Team
Diversion Tip Line Data Analysis Samples and Testing Education
Question? Which organizations currently have a Multidisciplinary Proactive Diversion Committee that meet on a regular basis? Multidisciplinary CSDPP Monitor & audit anomalous/suspicious users Monitor compliance topics with regard to policy
Standardize review practices Writing and editing policies and procedures Develop education & communication Diversion Tip Line 24/7 call in line
Anonymous and confidential Immediate action on reported individual Reporting user able to obtain updates Data Analysis Pharmacy Information System (PIS)
Pharmacy Unreconciled Dispenses Daily 222 Forms - Weekly Not Given CS Daily
Full of administration history - Monthly Separation of duties Purchase History vs Charge Files Monthly Anomalous Users Monthly
CS Inventories Automated Dispensing System (ADS) Open Discrepancies -Daily Closed Discrepancies - Daily OR Reconciliation - Daily
Pharmacy Compare Reports Daily Override Transactions - Daily Nursing Inventory Compliance Weekly and Monthly Removals After Discharge Weekly
Temporary Patients - Monthly Samples & Testing Random employee drug screens For cause drug screens Controlled Substance Waste
Human Resources Compliance Rehabilitation/Drug Courts Education Annual CBLs for staff handling CS
Rounding with clinical and administrative staff Controlled Substance accountability during nurse orientation Lessons Learned Understand the intricacies of workflow and staffing Communicate with front line nursing
Look at your data every way possible & keep an open mind Keep communication lines open Establish a baseline for education Ask Questions Take-Aways
Perform gap analysis for your facility Start with the low hanging fruit Open a dialogue across disciplines with feedback Questions? Resources ASHP Guidelines on Preventing Diversion of Controlled
Substances, American Journal of Health System Pharmacists 2017; 74:e10-33. Arkansas Department of Health, Pharmacy Services and Drug Control Branch, Rules and Regulations Pertaining to Controlled Substances, Dec. 1, 2014. Arkansas Prescription Monitoring Program, FY 2017 Third Quarter Report January March 2017. Drug Diversion in Healthcare, The Journal of Global Drug Policy
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