Steps to Control Drug Diversion

Drug diversion is a serious offence and DEA licensees cannot simply close their eyes to the possibility of this happening at their practice or facility. It is better to take proactive steps to nip the problem in the bud!

The Drug Enforcement Administration (DEA) is a branch of the U.S. Federal government that is tasked with preventing all kinds of drug related criminal activity including trafficking and diversion. For this, it enforces a range of controlled substance regulations, including veterinary DEA regulations, to regulate and license medical healthcare prescription drug distribution. They are quick to red flag and investigate even the slightest suspicions by putting a practitioner/practice under surveillance and instigating criminal proceedings if needed.

 

To avoid the heavy repercussions of a DEA investigation and criminal action, the registrants should take strict measures to prevent any kind of drug diversion or abuse in the first place. Such as:

• Do not print the full DEA registration number on the prescription - it is better to add only the last few digits by hand when writing out the prescription.
• Never leave the prescription pad unattended. Always keep it under lock when not in use.
• Limit the amount that is prescribed and refills authorized to the requisite quantity/number only.
• When issuing paper prescriptions, list both the number being prescribed and write out the amount in words.
• A good practice is to stick to prescribing certain prescription medications in specific strengths only. This will help highlight any deviations from the regular prescription and ordering patterns.
• Monitor the use of the practice’s credit card and checking account on a regular basis.
• Fill out order and refill forms with the utmost care.
• All controlled substances purchases should be carefully checked upon delivery prior to storage.
• Conduct regular audits to check for shortfalls, especially in the samples.
• Controlled substances should never be left lying around regardless of the reason or urgency. They should always be stored properly under lock and key in accordance with the specified norms.
• Never permit self-use of controlled substances by the staff.
• Require staff to verify dispensing and receipt of controlled substances in a clear manner.
• Ensure that only a single dose of a scheduled drug is drawn into a syringe for administering to a patient. This will nip the possibility of diversion of partial doses left in the syringe.
• Proper disposal norms should also be followed at all times.

It is observed that drug diversion and abuse does happen quite frequently despite utmost care and vigilance on the part of the DEA license holder. It is prudent to engage professional services to review the workflow and procedures, assess the potential risks, recommend improvements in the processes, train the staff and even implement changes in the policies and operations.

Being well-versed with the DEA veterinary and other requirements on a personal basis, the Titan Group is primed to identify issues and deficiencies that are easily overlooked. In fact, they offer comprehensive compliance solutions to avoid alarming visits from the DEA!