Case Study: Drug Diversion Guidance

Drug Diversion

A skilled nursing facility was first made aware of the possible diversion when they were advised by their pharmacy that refills were being ordered too soon and too frequently. In order to ensure that the investigation and corrective actions were in compliance with all state and federal regulations, as well as best practices, our client then contacted us seeking guidance and instruction for the investigation of possible drug diversion. 

Compliagent’s Actions: Compliagent consultants held conference calls throughout the investigation to advise the client with regard to the proper procedure for the investigation, including: suspension of suspected staff; comprehensive audit of medication carts and overflow; nursing license validation and board evaluations; staff interview procedure; in-service recommendations; and all other resource guidance up to and including resolution.

Outcomes: While the investigation had initially returned little to no results, once Compliagent intervened and began guiding the investigation, the “pieces of the puzzle” started coming together. Compliagent’s guidance allowed the client to understand the complete scope of the diversion, including the total number of medications diverted, the number of residents potentially affected, and the chain reaction of diversion within the entity. Compliagent works alongside our clients to sift through the details and determine the root of the problem, while keeping within regulations and best practices. As the investigation began to yield a final result, Compliagent advised the client of all required notifications and disclosures to ensure that they were in compliance with mandated reporting laws. Upon resolution of the investigation, Compliagent also educated the client on proper documentation techniques, recommended in-services, and necessary follow-up to safeguard against future potential diversion. 

The reception received from all involved parties was outstanding. While Compliagent consultants may view the scope of work as just “part of the job,” the client was both confident and relieved at the conclusion of the investigation. Employing best practices - such as due diligence, active support, and follow-through - provides peace of mind to all those involved and promotes success for the client. It’s one thing to simply send a few emails advising a client, however by speaking with the client and walking them through every step of the way – that’s what sets Compliagent apart. Our clients truly appreciate our hands-on approach. Diversion investigations are incredibly serious and stressful for any organization, but with the right compliance consultant and the right professional guidance, such risks can be easily mitigated, resolved, and prevented. 

“Compliagent’s team was very impressive in their immediate response and continued involvement. Right from the start, we felt confident in Compliagent's guidance and looked forward to seeing the investigation through with their support. We could not have been more pleased with their service.”  


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