Establishing a strong drug diversion response team
The diversion response team is a small, multidisciplinary group that examines data that suggests diversion (i.e., that provides “reasonable suspicion”) and determines what action to take. In some cases, that will mean intervening with and confronting the suspected diverter, and in others that may mean waiting and monitoring. The team is best led by an individual with a good understanding of controlled substance handling requirements, drug transaction reports, and analytics data (often the diversion specialist). This group typically includes up to six individuals, among whom should be representatives from human resources, nursing, and pharmacy. The manager or supervisor of the suspected employee is usually an ad hoc member of the diversion response team as well.
Regardless of the makeup of the group, patient safety considerations require that this team be able to convene on very short notice and after routine business hours. This may be accomplished by conference call if an in-person meeting isn’t feasible. A diversion response team email group is useful for communicating issues and concerns as they arise.
Experienced response team members are able to support and guide the manager of the suspected employee, given that most managers likely are not very familiar with the process of reviewing and investigating potential diversion. The response team also helps secure staff buy-in to the program and may make staff more likely to report concerns. Having an objective, multidisciplinary group review each case increases the likelihood that a diverter’s colleague will report suspicions by removing concern that the investigation will become a personal matter or that reporting a colleague will result in corrective action if the suspicion is unwarranted.
Another role of the diversion response team is to ensure that all potential diversion-related issues are fully investigated. The leader of the response team, typically the diversion specialist/program manager, should ensure that tasks are assigned when concerns arise. For example, if an empty fentanyl vial is found in the ICU staff bathroom, the leader of the response team might direct a nursing representative to interview the staff who found the vial, a pharmacy representative to run drug cabinet reports that might identify a staff member who is an outlier for fentanyl use, and another response team member to contact environmental services to determine when the bathroom was last cleaned in an attempt to zoom in on the time frame during which the vial was left there.
Editor’s note: This is an excerpt from Drug Diversion Prevention in Healthcare, Second Edition. Platinum members can read the e-book for free here.