ASHP Chapter 2 Controlled Substance diversion prevention Flashcards
Where is divertion found?
Areas most vulnerable to diversion
Area vulnerable to divertion:
1-pharmacy
— secluded areas with a unsecure controlled Substances,
A -compounding area.
B-Receiving area
2-procedural area
—-open access to anesthesia and pain medication
— ability to pull medication without prior order
3-patient home medication
Vulnerability in 5 areas:
1-Procurement
2-operations and dispensing.
3-prescribing
4-administration.
5-medication, waste and removal
Vulnerability in :
A—Process is often limited to only 1 to 2 people
1-limited oversight.
2-increased opportunity to diversion act
B–access to CS ordering methods
—222 forms
C—-potential for a diversion during transit
-Vulnerability in :Procurement
Vulnerability in ——?
1-limited oversight.
2-potential for tampering prior to preparation, return all waste.
3-potential for substitution while compounding and pre-packing
Preparation and dispensing
—Removal from safe, or ADCs
Vulnerability in .?
1-prescription pad, theft
2-Fraudulent or altered prescription
3-over prescribing.
4-self prescribing.
5-prescriptions outside of normal scope of practice
Prescribing
Vulnerability in:
1-diversion of medication documented as given.
2-administration of an alternative medication.
3-opportunity for tempering doing removal from ADCs
—-cancellation of removal transactions
—-return transaction that access the original pocket
Administration
Vulnerability with:?……
1-diversion of expired medicationi
2-waste of unused medication’s
—-partial and whole doses
3-diversion of unsecured waste
Vulnerability with medication, waste and removal
What can we do to prevent diversion for security control measures?
1 physical device.
2-diversion detecting and prevention software
To prevent for Security control measures :
1-cameras.
2-automated dispensing cabinets
Physical device
To prevent for Security control measures under:
1-example Pandora, RxAuditor,ADC reports
2-can we view historic ADC activities by drug or by user
3-diversion monitoring reports
—-proactive diversion
— waste buddies.
—-cancel transactions
4-program powered by artificial intelligent.
—-bluesight ,heliometric, invistic, protenus.
5-integrate information from automated dispensing cabinets, EMR, time clock, purchasing and receiving software
6-automatically, analyze, user, and transactions to identify an outlier
—diversion detection, and prevention software
Element of an effect controlled substance diversion programs:
A-only apply to CII in retail setting
B-perpetual inventory for all CS
C-monthly inventory of all CS in pharmacy.
D-weekly inventory or shift count in patient care areas
1-Storage
-lock all CS in pharmacy and patient care area
Element of an effective controlled substance diversion program under:
1-use of single access pockets.pp
2-blind count
3-fridge lock boxes.
4-External return bins
5-timely, discrepancy resolution.
6-audits of discrepancy resolution appropriateness
Storage:
—-Controlled substance in ADCs
Element of an effective controlled substance diversion program:1st
1-tamper evident bags for CS that can’t be sent home.
2-document on control substance administration record (CSAR)if use during patient stay is necessary
Storage:
Patient home meds
Element of an effective controlled substance diversion:
1-limit number of individuals with ordering privilege
2-CSOS
3-secure 222 forms
4-multi-pack locks for 222 dispensation
5-it would use identifying words in PO numbers( usually outside the delivery box) usually can tell
Ordering
Element of an Effective Controlled Substances Diversion programs: there are 8:
1-storage
2-ordering
3-Receiving
4-dispensing
5-prescribing
6-audit to monitor CS administration.
7-medication Waste
8-outdated medication.
1-verify accuracy before delivery driver leaves.
2-separation of duties.
3-oversight of CS receipt.
4-include 222 and invoice numbers on ADC receipt
5-attach ADC receipt to invoice and 222
Element of an effective control substance diversion program:
-Receiving
Element of an effective control substance diversion program:
1- Use of units dose packaging.
2-inspection of prepared products for tampering.
3-ADC compounding function.
4-limit number and type of CS store in patient care areas.
5-sending CS to a patient care area or ADC
—— load in ADC or document on CSARs
——— avoid sending patient specific.
6-Home meds
Dispesing
Element of an effective control substance diversion program:
1-prescription pads, and paper ——lock all prescription pads ——— individually numbers blanks —— store in ADC if possible 2-educate staff on prescribing issues —-signs of forgery (handwriting, variation, unusual, abbreviation, different color, ink) —-overprescribed he —-PMDPs 3-effective use of PMDPs —-CDC recommendations a-check all prescriptions at at least once every 3 months b-checking all Opioid prescriptions prior filling 4-some state and facility have specific requirements 5-important consideration —-not all state participate in PMDPs —— data, not always share from one to jurisdiction to the next —— frequency of data uploaded can verify state
Prescribing
Element of an effective controlled substance diversion programs:
-Monthly audit of anesthesia records
- include all anesthesia providers in audit
-Monitor appropriate documentation on anesthesia of all CS removed
-Monitor accurate documentation and witness of waste.
-Report findings to relevant parties
Audits to monitors CS administration
Anesthesia audits
Element of an effect a Controlled, substance diversion Prevention program:

1-review of all patient records to ensure adequate pain relief
2-interviews with patient not experiencing expected relief
Audit to monitor administration
Miscellaneous audits
Element of an effective controlled substance diversion program:
1-requires a witness for all waste
2-audit waste quantities
3-use of drug disposal systems
4-required documentation of all CS patch, patient control analgesia (PCA) waste
5-use of drug disposal systems
Sharp container
Medication waste
Element of an effective controlled substance diversion program:
-1-store in a lock location.
2-segregate from other CS storage
3-locked on pepetual inventory
4-include in all CS inventories.
5-reconciliation against reversed distributor report on pepetual inventory
4-include in ALL CS inventories.
5-reconciliation against reversed distributor report
Outdated medication’s
1-222 logs
2-monthly controlled substance sale report
3-safe ADC compare report.
4-CSARs and manual inventory.
5-prescriptions
6-compounding.
7-waste.
8-outdated, controlled substance
Chains of Custody methods
Chain of custody methods:
1-record dispensation of all 222s 2-multi pack logs
222 logs
Chain of custody methods:
Reconciliation CSnpurchase vs receipt
-
Monthly controlled substance sale report
Chain of custody methods:
1-review at least daily
2-reconciliation of CS sent to against received in patient care areas
Safe-ADC Compare Reports i
1-sequentially numbered forms
2-pharmacy review of completed forms prior to issuance of the next
3-pharmacy monitors transcriptions of beginning and ending counts
CSAR Manual inventories
1-contact providers to verify, suspicious or questionable prescriptions
2-lots of numbered prescription, Pads and paper
Chain of custody
-Prescriptions
Chain of custody methods:
1-use compounding function in a ADC vault to make kits and compounds
Compounding
Chain of custody methods:
1-document all waste in a ADC if applicable
Waste
1-compare perpetual inventory vs reversge distributor
Chain of custody:

-Outdated controlled substance
, there are 8:
1-222 Logs
2– monthly controlled substance sale report
3-safe-ADC compare reports
4-CSARs and manual inventories
5-prescriptions.
6-compounding.
7-waste.
8-outdated, controlled substance
The chain of custody methods
