1Drug Diversion in the Medicaid Program. (2012). https://www.cms.gov/Medicare-Medicaid-Coordination/Fraud-Prevention/MedicaidIntegrityProgram/downloads/drugdiversion.pdf2The Record (2014, July 18). Hospital chain fined $1.55 million for missing drugs. http://www.recordnet.com/article/20140718/A_NEWS/407180311 3Hospital’s Failure to Keep Proper Records Results In $2 Million Civil Fine. (2007, July 26). http://www.dea.gov/pubs/states/newsrel/chicago072607.html 4Prescription Medicine News Releases. Retrieved from http://www.dea.gov/pr/top-story/Prescription.shtml 55Diversion and Abuse of Controlled Substances in Hospitals. (2014, August). http://www.rm.imshealth.com/us-featured/Documents/HospitalDrugDiversionWhitepaper.pdf 6McClure R, O’Neal B, Grauer D, et al. Compliance with Recommendations for prevention and detection of controlled substance diversion in hospitals. Am J Health Syst Pharm. 2011; 68(8):689-694. 7Davenport, C. (2014, August 19). Patients infected by tainted saline that nurse substituted for stolen pain meds. https://www.justice.org/news/law-reporter-and-trial-news/aug-19-2014-pnlr-e-newsletter88Hanners, D. (2013, March 20). St. Cloud nurse gets 2 years for IV drug thefts that spread infection to 25 patients. http://www.twincities.com/ci_22834622/st-cloud-hospital-nurse-gets-two-years-stealing

What will compliance gaps in diversion managementcost you?

THE OUTCOME

Did not get dispensing reports. Did not have a plan for identifying diverters.Did not have a method to trace drug distribution.

The hospital was found at fault for FAILURE TO MONITOR7

given to diverter after pleading guilty year prison sentence82

plus legal fines from infected patients restitution fees8$340,000

Same bacteria in patients’ blood was found in a saline bottle

from diverter’s desk.

All were in the same post-surgical ward and all had received IV pain-killing narcotics.

cases of unusual bacterial blood infections725THE FACTS CASE STUDY

Collected by the DEA from 2007 - 20154

$145+ MILLION$2M$1.55M

Paid by a facility to settle record keeping deficiencies3 Paid by a facility

to settle claims ofmishandled controlled substances2

$10,000 FINE

“Drug diversion is best defined as the diversion of drugs from legal and medically necessary uses towards uses that are illegal and typically not medically authorized or necessary.” 1

- Centers for Medicare & Medicaid Services (CMS)

LACK OF PROCESSES FOUND AMONG PHARMACIES AND NURSING UNITS:

16% did not use automated vault for controlled substances6

21% did not have software to identify diversion6

34% never investigatedADC stockouts6