![Page 1: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/1.jpg)
The Role of Occupational Health in Diversion ResponsePRESENTED BY
KIMBERLY NEW, FOUNDING PARTNER
DIVERSION SPECIALISTS,LLC
COPYRIGHT ©2019 KIMBERLY NEW
![Page 2: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/2.jpg)
© 2019 KIM NEW
Environment We Work In
![Page 3: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/3.jpg)
© 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
![Page 4: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/4.jpg)
© 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
![Page 5: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/5.jpg)
© 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
![Page 6: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/6.jpg)
© 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
![Page 7: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/7.jpg)
© 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
![Page 8: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/8.jpg)
© 2019 KIM NEW
Why All Staff? Unfettered Access
![Page 9: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/9.jpg)
© 2019 KIM NEW
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
![Page 10: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/10.jpg)
© 2019 KIM NEW
Basics to be Aware Of
![Page 11: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/11.jpg)
© 2019 KIM NEW
Drugs of Choice
Injectables:
Hydromorphone
Morphine
Fentanyl
Propofol
Pills and liquids:
Hydrocodone
Oxycodone
Patches:
Fentanyl
![Page 12: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/12.jpg)
© 2019 KIM NEW
Other Drugs of Choice
Benzodiazepines (lorazepam, alprazolam, clonazepam)
Ondansetron, promethazine, diphenhydramine, acetaminophen
Cyclobenzaprine, ketorolac, gabapentin
Anesthesia gases, naloxone
![Page 13: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/13.jpg)
© 2019 KIM NEW
Addressing Diversion Systematically
![Page 14: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/14.jpg)
© 2019 KIM NEW
What is Your Organizational Approach?
![Page 15: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/15.jpg)
© 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
![Page 16: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/16.jpg)
© 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
![Page 17: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/17.jpg)
© 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
![Page 18: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/18.jpg)
© 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
![Page 19: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/19.jpg)
© 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
![Page 20: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/20.jpg)
© 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
![Page 21: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/21.jpg)
© 2019 KIM NEW
Trends to Be Aware Of
![Page 22: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/22.jpg)
© 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
![Page 23: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/23.jpg)
© 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/
![Page 24: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/24.jpg)
© 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
![Page 25: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/25.jpg)
© 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/
![Page 26: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/26.jpg)
© 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
![Page 27: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/27.jpg)
© 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
![Page 28: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/28.jpg)
© 2019 KIM NEW
Other Trends:
Staff coming in while on leave
Staff diverting upon return from medical leave
![Page 29: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/29.jpg)
© 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
![Page 30: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/30.jpg)
© 2019 KIM NEW
Your Efforts Could Save a Life
![Page 31: The Role of Occupational Health in Diversion Response · © 2019 KIM NEW Regulatory Environment University of Michigan-$4.3 million Effingham Health-$4.1 million Mass General - $2.3](https://reader034.vdocument.in/reader034/viewer/2022050522/5fa5ba6313e305690146121a/html5/thumbnails/31.jpg)
© 2019 KIM NEW
Questions
C O N T A C T :
K I M B E R L Y N E W
K I M B E R L Y @ D I V E R S I O N S P E C I A L I S T S . C O M