The COVID-19 pandemic has caused many challenges and increased the risk of drug diversion within organizations. Since COVID-19 began, there has been a lack of monitoring and tracking, staffing shortages, and an increase in inadequate coping skills due to highly stressed healthcare workers. The pandemic has caused a constant change in workflows with no time to monitor compliance. With relaxed restrictions on medications, it has been easier than ever for staff and providers to gain access to controlled substances. This presents an opportunity to discuss the signs of drug diversion, prevention methods, and how to report it.
Healthcare providers have been at the forefront of the pandemic, and challenges include working short staffed, emotional demands, long hours, and an increase in patient volume. The impacts of drug diversion for healthcare providers include:
- Risk of overdose and death,
- Regulatory penalties,
- Criminal prosecution, and
- Malpractice – increased risk of impaired healthcare providers.
For healthcare systems, drug diversion can impact the care of patients. According to the Medicare Conditions of Participation, “Hospitals must provide a safe care environment for patients, with prevention of tampering and substitution and must have ongoing surveillance to identify infectious risks, communicable disease concerns.” 
Healthcare systems can also face civil and criminal penalties, financial loss (the annual drug diversion cost in the United States is estimated at $25 billion) , and lose the trust of the public.
- Legal liability for employees – If an employee of the healthcare system or organization is suspected of drug diversion, the system or organization can be held liable for negligence if there is an incident that involves a patient.
- Compliance/regulatory – Organizations need to ensure they have compliance policies and procedures in place to review, track, and view drug dispensing data. With this information, organizations can look further into data related to drug utilization by provider.
- Inconsistent work schedule,
- Inadequate preventative measures in the work environment to limit access,
- Verbal order for controlled substances is created but not verified by a prescriber,
- Patients complaining of inadequate pain control,
- Unusual patterns of pain medication removal, and
- Lack of effective treatment (e.g., ADHD).
What to do when you suspect drug diversion
If you are an employed provider or staff member of a healthcare system and you suspect drug diversion, please consult your organization’s risk management department for advisement as to system policy or protocol.
According to Healthcare Diversion Network, a nonprofit association solely committed to preventing drug diversion, “if the person suspected of diverting is a nurse, pharmacist, physician, or other licensed healthcare professional: Report the healthcare worker to their professional licensure board within your state, such as the state Board of Nursing, Board of Pharmacy, or Medical Board.” 
For non-licensed medical professionals:
- Local law enforcement and local fraud alert networks
- DEA, for reporting theft or loss of controlled substances, at https://www.deadiversion.usdoj.gov/21cfr_reports/theft/index.html
- U.S. Department of Health and Human Services, Office of Inspector General (HHS-OIG) by email at HHSTips@oig.hhs.gov or by telephone at 1-800-HHS-TIPS (1-800-447-8477); TTY: 1-800-377-4950.
Below are practices that will mitigate the risk for drug diversion and support medication safety. A few small steps can go a long way in helping everyone, from clinicians to patients.
- Limit the number of individuals who can purchase medication. Separate the purchasing and receiving roles.
- Ensure that medications are in tamper evident packaging.
- Ready to administer, exact dose required.
- Minimize the number of staff who has access to medication – ensure that carts, cabinets, and other areas containing medications are always locked when not in use.
- Ensure that there is a policy in place for removal and inventory verification of medications.
- Conduct audits regularly to ensure that all medications have been accounted for.
- Verify all medication measurements – avoid waste of medications.
- Dispensing Prescriptions
- Verify all medications before dispensing. Ensure that all medications have the correct quantity before dispensing.
- Improve system reliability – forced functions.
- Waste, return, and disposal
- Enforce witnessing and signature.
- Ensure that there is a secured area for wasted and expired drugs.
Risk Management Strategies
- Assess the ways in which healthcare workers gain access to medication. Utilize a systematic approach to identify vulnerabilities within the system and revise workarounds if needed. High-risk areas include the ICU, emergency department, surgery, long-term care, oncology, and psychiatry.
- Analyze staffing ratios, encourage leadership, and peer support.
- Create a culture of safety and personal accountability. Establish a culture that emphasizes “see something, say something.” Emphasize that reporting drug diversion is encouraged.
- Utilize short webinars on drug diversion or send out email reminders on why reporting suspected drug diversion will help the organization. In addition to educating staff on diversion and outlining the problems, review policies on reporting suspected drug diversion to clinical supervisors. 
Resources and More Information
- Centers for Disease Control and Prevention: Drug Diversion https://www.cdc.gov/injectionsafety/drugdiversion/index.html
- Joint Commission: Quick Safety – Drug Diversion and Impaired Health Care Workers https://www.jointcommission.org/-/media/tjc/newsletters/quick_safety_drug_diversion_final2pdf.pdf
If you are an employed provider of a healthcare system and have questions on this subject, please consult your organization’s risk management department for advisement as to system policy or protocol.