Chapter 2 Control Substance Drug Diversion Flashcards
It is any criminal act or deviations that removes a prescription from its intended path from the manufacture to the intended patient
What is drug diversion?
Types and functions of security control measures, devices, and software to detect and prevent diversion
Nursing managemen
Audit
Automated dispensing devices
Camera systems
Discrepancy measures
Documentation guidelines.
. 
High risk areas of the pharmacy
The Pharmacy itself
In transition.
Receiving
Narcotic volt?
Operation rooms
Will call
IV room
emergency department
Element of a comprehensive and effective controlled substances diversion prevention programs (csdpp)
— Core administration elements
Legal and regulatory requirement.
Organization, oversight, and accountability.
—System level control.
Human Resources management
Automation and technology.
Monitoring and surveillance
Investigation and reporting.
— provider level controls.
Chain of custody.
Storage and security
Internal pharmacy control
Prescribing and administration?
Returned, waste, and disposal.
-Procurement, prescribing, and administration and transfer of controlled. Substances are highly regulated by federal/state laws and compliance is Sanders.
-Billing and fraud implications
-DEA registrations.
-Patient all medication’s, medical cannabis, marijuana, and illicit substances
Core administration elements
-Legal and regulatory requirement
-Controlled substance management program should be in place with proven compliance
-authorized personnel trained.
-inter disciplinary committee to provide leader ship, and direction
-Drug diversion respond team
Core administration element
-Organization, oversight, and accountability
-Human resource management
-Automation and technology
-Monitor and surveillance
-investigation and reporting
System -level controls
-implement policy to protect patient from potential harm related to substance abuse and diversion
-orientations and annual education.
-Support recovery
System level controls
-Human resource management
Interdisciplinary team to select and implement all medication related automated systems and technology.
-Record keeping.
-Systems used in high-risk area.
-Authorized personnel trained
-Policy and procedures for downtime
System level controlled
-Automation and technology
Implement policy to protect patients from potential harm related to substance abuse and infection.
Orientation an annual education
Support recovery.
System level control.
-Human resource management
Interdisciplinary teams to select and implement all medication related—?
.?..
Record keeping.
Systems use in high risk area.
Authorized personnel trained
Policy and procedure for downtime
System level controls.—-automation system control
-Automation and technology
-Compliance reviews,
-surveillance trends
-Completeness of investigation and reporting
-confirmed corrective action.
-Diversion prevention, system improvements
System level controls
-Monitoring and surveillance
-guidance on who will conduct the investigation
-Investigation are conducted throughly and completely as possible.
-If an employee is arrested for illicit use of controlled substances, and investigation should occurred
-guidelines for engaging external entities.
-DA form 106 unresolved discrepancy
System level controls.
—Investigating and reporting.
-transfer of controlled substance occurring between individuals whether internal or external
-Ensure the integrity and security of controlled and safety of personnel transporting.
-Control substances in emergency medical services should comply with local and state and requirements
Provider level controls.
-Chain of custody
-stored in locked and secured location
-locked out times for electronic lock on count.
-Only authorized personnel have access.
-Way to track keys if needed
-video surveillance in high traffic areas
-Automated dispensing utilize.
-Pharmacy inventory is monitored.
-Narcotic count as verify each time in area is access with control substance
Provider level controlled.
— storage and security
-Procurement controls
— always procured from the pharmacy.
— purchasing safeguards.
—-electronic ordering system— no paper 222 forms
—— to Authorized individuals count and narcotics.
—-process in place to discrepancies
—-control and documentation for transferred to another pharmacy.
—-paperwork is audited.
Providers level controls.
-Internal pharmacy controls
—— procurement control
-perpetual inventory.
-Blind check when removing narcotic.
-Access to inventory is limited.
-Drug products inspected
for tampering
-unit dose packaging is purchased when available.
-Delivery off narcotics should have auditable verification.
-Returned should have an editable procedure

Provider level control
-internal pharmacy controlled.
— preparation and dispensing controls
-narcotic should be in ready to use form
-Unused medication should be disposed of immediately
-When wasting, there should be a witness.
-All disposal guidelines in accordance with a recommendation Guidelines
-Waste container should not allow for the retrieval of any medication.
-Items that are reusable should be returned to automated machine with witness.
-Expired narcotic should be clearly labeled.
-D EA Registrant or destiny should assist with all phase of narcotic disposal
Providers level controls
-Return, waste and disposal
-controlled substances can only be ordered by licensed authorized prescriber with DEA authorization
-there should be a process in place to identify the prescriber.
-Refills and time authorization should be within limited range.
-Prescriber should not prescribe for themselves for family (not ethical)
-Or syringes with narcotic are labeled
-Process in place when automated devices are not use for administrator purpose
Provider level control
— prescribing and administration
-procurement
-Preparation and dispensing.
-Describing
-administrations
-Waste and removal
Areas of vulnerability
-purchase order or package slip Remove from records
-unauthorized individuals order for control substance on stolen DEA phone 222
-Product container compromise
Area of vulnerability
—Procurement
-CS are replaced by product, similar appearance when repackaging
-Removing volume from premixed infusion
-Multidose vial overfill diverter
-Prepare syringe content I replaced with saline solution
Area of vulnerability
—preparation, and dispensing
-Prescription Pad and I bought it in for to obtain CS
-Prescriber self prescribed CS
-Verbal orders for Cs create , but not verified by provider
-written prescriptions altered by patience
 Area of vulnerability
— prescribing
-CS withdraw from an automated dispensing device on discharged or transferred patient.
-medication document ask given, but not administered to patient
-waste is not adequately witnessed and subsequently diverted
-substitute drug is removed and administered while CS is diverted 
Area of vulnerability
— administration
-CS waste is removed from unsecure waste
-CS waste in syringe is replaced with saline
- expired CS are diverted from holding area
Area of vulnerability
— waist and removal
-an employee cannot alter the audit tree for the chain of custody
-Measures should be in place to ensure the integrity and security of CS and the safety of personnel, transporting CS to offsite location
-Secure, lockable, and tampering evident delivery containers that do not make know what is being transported
-should be traceable.
-Audit tray should be maintained at all times and at a point when they transfer of CS occur between individual
—-carrier transferred to other facilities
— use of pneumatic tube system
— transfer to emergency medical service provider
— transfer from Contacts pharmacy services
Chain of custody
Learning objective
-Area of vulnerability in procurement, preparation, and dispensing, prescribing, administration, and waste/removal process.
-Element of comprehensive and effective Controlled Substances, Diversion Prevention program(CSDPP)
-type and function of security control measures, devices, and software to detect and prevent divergent. (Example looking storage, cameras, ADC, analytics, software.)
-high risk areas of the pharmacy ( eg anesthesia areas , CS vault,IV room,, will call, receiving)
-chain of custody method s ( eg
regulation of access control, presence of witnesses for signing delivery sheets, use of tampering evident containers )
-Chain of custody.
-Storage and security.
-Internal pharmacy control.
-Waste returns and disposal.
-Prescribing and administration
Provider level control
-procurement
-Preparation and dispensing.
-Prescribing
-Administration
-Waste and removal.
Areas of vulnerability
-purchase order and packing slip removed from records.
-Un authorize individual order for CS on stolen DEA form 222
-Product container compromise
Areas of vulnerability
—Procurement
-CS are replaced by product of similar appearance when repackaging
-removing volume from premixed infusion.
-Multiple dose overfilled diverted
-Repair syringe contacts are replaced with saline solution
Areas of vulnerability
—Preparation and dispensing
-Prescription pads , diverted and forged obtain CS
-Prescriber self prescribed CS.
-Verbal orders for CS created , but not verified by prescriber
-Written prescription altered
by patient
AREAS of Vulnerability
Prescribing
-CA a Re withdraw from an automated dispensing device on discharge or transfer patient
-medication documented as given, but not administered to patient
-Waze is not adequately witnesses and subsequently a diverted
-Substitute drug is removed and administered it while CS is diverted
Areas of Vulnerability
-Administration
-
Cs is waist is removed from unsecure waste container -
-CS waste in syringe is replaced with saline.
-expired CS are converted from holding area
Area of vulnerability
—Waist and removal
