Drug Diversion Fines and Enforcement Actions at Hospitals and Other Healthcare Facilities

An Invistics Webinar

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