On December 13th, Madeline Hultquist attended the “Drug Diversion Fines and Enforcement Actions at Hospitals and Other Healthcare Facilities” webinar. The event, hosted by Invistics, consisted of a presentation that reviewed drug diversion prevention best practices in hospital settings and investigated multiple case studies where hospitals or health systems were found to be non-compliant.

Keynote Speaker:

• John Gilbert – Director at Hyman, Phelps & McNamara

Host:

• Tom Knight – Founder & CEO of Invistics

Key Takeaways:

• Main risks of controlled substance diversion and abuse include:
  • Public safety and public harm
  • Regulatory and legal liability to the organization
  • Administrative, civil, and/or criminal penalties
• Common risk points of diversion include:
  • Security and storage of controlled substances
  • Prescribing, dispensing, and administration
  • Waste and disposal
• Enforcement is becoming more complex and in-depth as multiple groups work together in ‘tactical diversion squads’ to coordinate their investigations.
• Best practice is to ensure accuracy and accountability when it comes to controlled substances.
  • This means ensuring records are accurate through regular auditing and monitoring and having Automated Dispensing Machines with cameras.
  • This also means enforcing prompt action when an issue arises: report the suspected drug diversion as soon as possible, hold a timely investigation, and enforce disciplinary actions as needed.
• Resources to follow for drug diversion information:
  • FDA Law Blog, www.fdalawblog.net
  • Administrative Actions Against Registrants, DEA Office of Diversion Control, https://www.deadiversion.usdoj.gov/crim_admin_actions/
  • DEA, https://www.deadiversion.usdoj.gov/

To learn about Trexin’s Drug Diversion Practice Area, click here:

Drug Diversion Practice Area