Controlled Substance Drug Diversion Toolkit
Controlled Substances Drug Diversion Toolkit
Drug diversion can be defined as any criminal act or deviation that removes a prescription drug from its intended path from the manufacturer to the intended patient. As stated in the ASHP Guidelines on Preventing Diversion of Controlled Substances1, “Controlled substances (CS) diversion in health systems can lead to serious patient safety issues, harm to the diverter, and significant liability risk to the organization." These guidelines outline a collaborative, interdisciplinary approach to and accountability for CS diversion prevention and response within an organization. The purpose of this toolkit is to provide additional resources for health care organizations working to implement a comprehensive Controlled Substance Diversion Prevention Program.
ASHP Controlled Substance Diversion Prevention Program (CSDDP) Assessment Tool
The ASHP Controlled Substances Diversion Prevention Program (CSDPP) Assessment Tool serves as a practical resource to help organizations determine how their site aligns with the best practice recommendations provided in the ASHP Guidelines on Preventing Diversion of Controlled Substances. Upon completion of the gap assessment, the results identify areas for improvement and allow the user to develop an action plan for their organization.
Sample Controlled Substances Drug Diversion Pharmacy Technician Position Descriptions
- Diversion Monitoring Project Manager [PDF]
- Pharmacy ADC Quality Coordinator [PDF]
- Pharmacy Loss Prevention Specialist [PDF]
Processes and Workflow Resources
- ASHP Guidelines on Preventing Diversion of Controlled Substances [PDF]
- Drug Diversion Core Team Investigation Report [PDF]
- Example of steps in investigating a potential drug diversion incident [PDF]
Diversion Vulnerabilities
It is estimated that 1 in every 10 (10%) of all healthcare professionals will divert controlled substances and other drugs at some point in their professional career2. In a 5-year study period from 2015-2019, health systems dispensed over 1 billion opioids per year3. Due to the large volume of controlled substances dispensed from health systems daily, technology-based diversion tracking programs with staff dedicated to monitoring are an essential part of combatting diversion.
Diversion Resources
- Centralizing a controlled substance compliance and drug diversion prevention program within a multihospital health system (AJHP)
- National Hospital and Health-System Controlled Substance Drug Diversion Prevention & Surveillance Program Assessment Survey - 2021 (AJHP)
- Controlled substance diversion in health systems: a failure modes and effects analysis for prevention (AJHP)
- Risks of controlled substance drug diversion (AJHP)
- Detecting drug diversion in health-system data using machine learning and advanced analytics (AJHP)
- Quick Safety - Drug Diversion and Impaired Healthcare Workers (TJC)
- Drug Diversion (HHS)
- Drug Diversion Division (DEA)
- Prescription Drug Monitoring Programs (PDMP) (CDC)
- Mitigating Drug Diversion in Ambulatory Procedural Areas (March 2022)
- Back to Basics: Perspectives from a CRNA on Preventing Drug Diversion (February 2022)
- ASHP Drug Distribution and Control Resource Center
- National Association of Drug Diversion Investigators
- International Health Facility Diversion Association
- CMS Drug Diversion Toolkit [PDF]
Communicating with Law Enforcement
Should you report to local law enforcement in addition to the DEA?
In the majority of the states, reporting to local law enforcement is not mandatory like reporting to the DEA and professional licensing boards. That being said, the DEA does offer support reporting drug diversion incidents to law enforcement as prompt notification to law enforcement will allow them time to investigate the incident and potentially prosecute those responsible for the diversion.
Reporting to local law enforcement may be the only way to help ensure an individual that has diverted is not able to go to another facility where they may cause further harm to patients by diverting again.
Resources for Addiction, Healing, and Recovery
Many employers provide Employee and Family Resource Programs that include substance abuse services. These services may be tailored to provide individualized care and support. In addition to your employer, some state pharmacy societies also provide substance abuse services. Listed below are other links that provide information on alcohol or substance misuse.
- Start Your Recovery
- Narcotics Anonymous
- Seeking Drug Abuse Treatment: Know What to Ask
- Substance Abuse and Mental Health Services Administration (SAMHSA) national helpline
1-800-662-HELP (4357) or 1-800-487-4889 (TDD — for hearing impaired).
This hotline can provide free and confidential information for individuals and family members facing substance abuse and mental health issues. You can call 24 hours a day, 7 days a week. - Buprenorphine Treatment Practitioner Locator
Find physicians authorized to treat opioid dependency with buprenorphine by state. - Overdose Prevention Toolkit
A guide to opioid use, overdose, recovery, and facts for community members. - Partnership for drug-free kids
A non-profit supporting families struggling with a child’s substance use. You can call the helpline at 1-855-378-4373, live chat, or email them for more information, resources or help. - Directory of Single State Agencies for Substance Abuse Services
A directory of state-funded drug treatment facilities.
Continuing Education, Certificates, and Podcasts
- ASHP Controlled Substance Diversion Prevention for Pharmacy Technicians (Education & Training Program for the PTCB Assessment-Based Certificate Program)
- Life Cycle of Diversion Prevention Software Implementation (Webinar - Member Only)
- Mind the Gaps: Update on Best Practice Guidance to Mitigate Controlled Substance Diversion (Webinar - Member Only)
- Controlled Substances Diversion: Creating a Value Proposition for All (ASHP Podcast)
References
- ASHP Guidelines on Preventing Diversion of Controlled Substances. (2022), American Journal of Health-System Pharmacy, Volume 79, Issue 24, 15 December 2022, Pages 2279–2306, https://doi.org/10.1093/ajhp/zxac246
- Better awareness and data-driven tools are first steps in combating drug diversion (2023). Wolters Kluwer. https://www.wolterskluwer.com/en/expert-insights/awareness-data-driven-tools-are-first-steps-combating-drug-diversion
- Khouja, T., Tadrous, M., Matusiak, L. M., & Suda, K. J. (2021). Opioid prescribing in United States health systems, 2015 to 2019. Value in Health, 24(9), 1279–1284. https://doi.org/10.1016/j.jval.2021.04.1274
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