Development of a Road Map to Controlled Substance Diversion Prevention Rene Cronquist, RN, J.D. Director of Practice and Policy Minnesota Board of Nursing
In the news. Prison Sought for Nurse Who Stole Drugs Nurse Accused of Stealing Patient s Prescription Nurse Pleads Guilty to Stealing Narcotics from Patients
Concerns Patient safety Patients deprived of necessary pain medications Potential for overmedication if subsequent doses are adjusted based on lack of pain relief Infection (contaminated IV meds) Nurse impairment while on duty Fear, reluctance to trust nurses Cost
Beyond the headlines Controlled substance diversion is a problem that concerns a number of parties. Each party had been addressing the problem from their point of view, with little coordination among the parties.
How to build a better mousetrap May 2011 the Minnesota Department of Health and the Minnesota Hospital Association assembled a coalition of stakeholders to address controlled substance diversion. Many of the parties that ultimately became involved in this project had a history of working together on other patient safety issues through the Minnesota Alliance of Patient Safety (MAPS).
The Coalition Participants included representatives from: Associations of health care organizations Infection Control County attorney Law enforcement local, DEA and FDA Large health systems Retail pharmacy & health system pharmacists Health Boards (Nursing, Medicine, Pharmacy) Boards alternative monitoring program (HPSP)
Narrowing the Universe The Coalition quickly realized the problem of drug diversion is vast and multifaceted. To be timely and effective, the group decided to be clear and concise about its focus. The focus became controlled substance diversion (as opposed to all drugs that might be diverted) and the acute care setting (hospitals).
Objectives Identify best practices and resources to prevent and increase awareness of diversion. Guidance to parties on how, when and with whom information may, can and/or must be shared. Recommend measures to quantify cases of diversion. Disseminate information to health care providers and organizations and the public.
How to accomplish the work Work groups Best practices/resources for prevention, awareness and detection of diversion Communication across coalition organizations and investigative organizations State and Federal reporting obligations Dissemination of resource materials Identification of measurements to gauge scope of the issue and impact of the coalition work
Prevention Roadmap Outline SAFE infrastructure Best Practices Principles Tool Kit
SAFE S: Safety teams/organizational structure A: Access to information F: Facility expectations E: Educate staff and patients
SAFE infrastructure Organization defines, and the structure supports, an effective CS diversion prevention program Proactive collaboration with law enforcement Commitment to collection, auditing and review of relevant data Organization sets and communicates expectation that staff speak up when a potential diversion concern is identified HR practices support organization-wide diversion program
Best Practices Procurement Storage and security Prescribing Preparation and dispensing Administration of CS Handling wastage Follow-up if diversion is suspected
Tools in the Tool Kit Includes: State and Federal laws and rules Diversion Prevention Coordinator position description Internal investigation checklists Diversion investigation agencies Diversion reporting obligation flow sheet Articles and websites regarding substance abuse and identifying the impaired practitioner
Diversion Investigation Teams Recommendation for a team to respond to any irregularity in controlled substances. Team assists with determining what investigation is appropriate and coordinates or assists with coordination of investigation. Examples: Code N or Drug Diversion Investigations Resource Team (D DIRT) Includes reporting to external agencies (e.g. law enforcement and Boards)
Outcomes of the Process Very beneficial to have the wide array of participants. In addition to identifying best practices, the coalition members developed helpful connections with other members. Better understanding of the roles, perspectives and challenges of each party. (Knowing who to call about what and when) Greater buy-in More outlets for dissemination of information
Disseminate information Encourage adoption of best practices Continued communication among coalition members Measure effectiveness Develop tools for other healthcare settings Next steps
Report, Roadmap and Toolkit http://www.mnhospitals.org/inc/data/drug-diversion-toolkit/drugdiversion-final-report-march2012.pdf http://www.mnhospitals.org/inc/data/drug-diversiontoolkit/controlled-substance-diversion-prevention-roadmap.pdf The Minnesota Hospital Association - Controlled Substance Diversion Toolkit All of the above will soon be posted on Board s website: www.nursingboard.state.mn.us