the role of occupational health in diversion response · © 2019 kim new regulatory environment...

The Role of Occupational Health in Diversion ResponsePRESENTED BY

KIMBERLY NEW, FOUNDING PARTNER

DIVERSION SPECIALISTS,LLC

COPYRIGHT ©2019 KIMBERLY NEW

© 2019 KIM NEW

Environment We Work In

© 2019 KIM NEW

Regulatory EnvironmentUniversity of Michigan-$4.3 million

Effingham Health-$4.1 million

Mass General - $2.3 Million Settlement

$10,000 civil violation including negligently failing to keep appropriate records

© 2019 KIM NEW

Current Climate

“At a time when our country’s opioid crisis is ravaging communities across the country, hospitals…have a critical responsibility to ensure that controlled substances are tracked and safeguarded from theft or loss and are not diverted for illegal uses…This record-setting civil penalty is a proactive step that DEA Diversion and our partners in the U.S. Attorney’s Office can take to discourage other healthcare providers from engaging in such reckless behavior.”

https://www.justice.gov/usao-sdga/pr/southern-district-georgia-announces-largest-hospital-drug-diversion-civil-penalty

© 2019 KIM NEW

Current Climate"This case should alert all health systems – large or small – that complying with the Controlled Substance Act is not only their legal responsibility but also a matter of public trust."

https://www.dea.gov/press-releases/2018/08/30/record-settlement-reached-university-michigan-hospital-drug-diversion

© 2019 KIM NEW

We Are All At Risk

SELF MEDICATION

FOR PAIN, ANXIETY,

DEPRESSION

“EXTENSION” OF LEGITIMATE PRESCRIPTION

CURIOSITY-PRIOR

HISTORY OF DRUG

ABUSE

STEALING FOR

OTHERS

SALE

© 2019 KIM NEW

All Staff Need Education❖Recognize vulnerabilities

❖We are all at risk

❖Avenues for self reporting

❖Avenues for reporting concerns about a colleague

❖Case studies-risks and successes

© 2019 KIM NEW

Why All Staff? Unfettered Access

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We All Have a Role

EVS worker and ED charge nurse

Billing analyst and charges for oral doses

Nurse accessed ADC during days not scheduled on units she wasn’t assigned to

Dietary aide reported patient’s concerns

Nurse in recovery had no trouble finding fentanyl

© 2019 KIM NEW

Basics to be Aware Of

© 2019 KIM NEW

Drugs of Choice

Injectables:

Hydromorphone

Morphine

Fentanyl

Propofol

Pills and liquids:

Hydrocodone

Oxycodone

Patches:

Fentanyl

© 2019 KIM NEW

Other Drugs of Choice

Benzodiazepines (lorazepam, alprazolam, clonazepam)

Ondansetron, promethazine, diphenhydramine, acetaminophen

Cyclobenzaprine, ketorolac, gabapentin

Anesthesia gases, naloxone

© 2019 KIM NEW

Addressing Diversion Systematically

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What is Your Organizational Approach?

© 2019 KIM NEW

Developing a Proactive ProgramOversight Committee Membership

Anesthesia Nursing Pharmacy SecurityRisk

Management

AccreditationChief Medical

OfficerInfection

PreventionHuman

ResourcesQuality/Safety

Occupational Health

Finance/Internal Audit

Compliance Research

© 2019 KIM NEW

Developing a Proactive ProgramOversight Committee Membership

Anesthesia Nursing Pharmacy SecurityRisk

Management

AccreditationChief Medical

OfficerInfection

PreventionHuman

ResourcesQuality/Safety

Occupational Health

Finance/Internal Audit

Compliance Research

© 2019 KIM NEW

Oversight Committee Functions

High level with ability to provide resources

Direct and support efforts

Subcommittees and workgroups may be helpful (ie, outpatient, anesthesia)

Annual goals-address gap analysis findings

© 2019 KIM NEW

Response Team FunctionsSmall team (Nursing, HR, Pharmacy, Supervisor)

Data driven suspicion (impairment handled per policy)

Problem solving (investigation of non-diversion CS issues)

Defined workflow/process-email group

Early structural component-must have as program ramps up

© 2019 KIM NEW

Diversion Prevention Specialist

Operations of program

Day to day accountability

Develops and provides: EducationSurveillance/auditingPolicy development

Collaborates with internal and external stakeholders

© 2019 KIM NEW

Role of Occupational Health•Pre-employment screening

• Assess for likelihood of drug security breach

•For cause testing

• Value?

•Support and monitoring for staff in recovery

© 2019 KIM NEW

Trends to Be Aware Of

© 2019 KIM NEW

Tampering in the Headlines

Iowa nurse indicted on charges of diverting hydrocodone and morphine and attempted to cover up the morphine theft by replacing the vials with mouthwash

https://www.thegazette.com/subject/news/public-safety/former-manchester-nurse-katie-boll-accused-of-stealing-hydrocodone-pills-morphine-20190716

© 2019 KIM NEW

Tampering in the Headlines

May 2019—Cleveland nurse allegedly removed a portion of opiate liquid and added water to the bottles in an

attempt to conceal the theft, thus diluting the

drugs.

April 2019—Denver nurse pleaded guilty to stealing

fentanyl vials, refilling them with saline and returning

them to the Pyxis

https://www.cleveland19.com/2019/05/17/nurse-pleads-not-guilty-stealing-drugs-patients-lakewood-nursing-home/https://www.denverpost.com/2019/06/25/fentanyl-parker-adventist-hospital-icu-nurse/

© 2019 KIM NEW

Tampering in the HeadlinesMarch 2019—Jacksonville nurse removed multiple syringes of hydromorphone, injected herself, refilled the empty syringes with saline and returned them.

https://www.miamiherald.com/news/health-care/article227497059.html

© 2019 KIM NEW

Tampering in the HeadlinesMarch 2019—Pennsylvania nurse charged with using morphine out of vials and replacing the morphine with another liquid.

February 2019—A traveling nurse in Roanoke tampered with vials of fentanyl and replaced the fentanyl with saline.

http://www.altoonamirror.com/news/local-news/2019/02/former-nurse-accused-of-stealing-morphine/https://www.southwesttimes.com/2019/02/traveling-nurse-sentenced-for-tampering-with-drug/

© 2019 KIM NEW

Staff Aren’t Aware of the RiskWhen evidence of tampering is found:

❖98% say they would waste the item

❖Several say they would use the item

© 2019 KIM NEW

Addressing Tampering❖Education is vital — signs are often attributed to a product defect

❖When tampering is suspected, BBP testing of suspected staff member should be the priority

❖BBP testing usually at time of UDS — handled like occupational exposure

© 2019 KIM NEW

Other Trends:

Staff coming in while on leave

Staff diverting upon return from medical leave

© 2019 KIM NEW

Remember…

Diversion is a pervasive risk to patients, staff, the institution and the community

Be alert to areas of risk

Constant vigilance is required

Occupational Health has a key role in protecting staff and patients

© 2019 KIM NEW

Your Efforts Could Save a Life

© 2019 KIM NEW

Questions

C O N T A C T :

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