the role of occupational health in diversion response · © 2019 kim new regulatory environment...
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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
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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
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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
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Addressing Diversion Systematically
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What is Your Organizational Approach?
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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
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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
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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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