G Gara Wilsie DPh Remedi SeniorCare ROOkkla G Oklahoma City Ok 73108 Learning Objectives What is Diversion of drugs and why does it happen What are the signs to watch for What policy and procedures should be in place to decrease the risk of diversion ID: 746695
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Slide1
Drug Diversion In Long Term Care
G
Gara
Wilsie, D.Ph.
Remedi
SeniorCare
ROOkkla
G
Oklahoma City, Ok 73108Slide2
Learning Objectives
What is Diversion of drugs and why does it happen?
What are the signs to watch for?
What policy and procedures should be in place to decrease the risk of diversion?Checklist for investigation of diversion?Anticipated changes to prevent diversion?
2Slide3
Control Medication Diversion
Diversion
of
drugs: Unlawful channeling of regulated pharmaceuticals, including the misuse of prescription medicationsSymptom of the disease of addiction Addiction is a treatable diseaseSlide4
Reasons for Diversion?
Personal use by staff
90% of Americans struggling with addictions are not currently getting treatment
In 2016, 11.5 million persons misused prescription opioids and 116 persons died every day from opioid related drug overdosesUse by related person to staff
Sale of medications:
Hydrocodone $3-$7/tablet
Alprazolam $1-$5/tabletSlide5
Healthcare Professionals and Drug Abuse:
Types
of drugs preferred:
60% use an opiate45% use a benzodiazepine11% use sedatives3.5% use amphetamines1.9% use inhalants
Early Intervention
is vital for both patient care concerns and health care employee professional
recovery
A
visible program
is a major deterrent to diversion
(Lillibridge, Cox & Cross, 2002)Slide6
Drug Diversion Issues: Staff
10
–20% of nurses have substance abuse issues
ANA estimates approximately 6% to 8% of nurses are practicing while impaired
Substance
abuse is the number one reason named by state boards of nursing for disciplinary
action
Recidivism
rates by nurses from diversion and rehabilitation programs are lower when compared with the general population
(Griffith, 1999); (Trinkoff& Storr, 1998
)
(Sullivan & Decker, 2001).Slide7
Staff Risk Factors:In the workplace:
Stress
Belief in medications-back pain, headaches
Caregiver BurnoutAccess to control Substances
At high risk: Staff who administer drugs daily and perceive poor to non-existent workplace controls have 2 X the risk of drug misuse.Slide8
Physical Signs of Use/Withdraw
Physical signs of use or
withdrawal:
Hand tremorsHeadacheDiaphoresisAbdominal/muscle crampsNausea/ DiarrheaIrritability or RestlessnessSigns may disappear with use
Non-descript: can
also be signs of psychological
problems.
Behaviors
impair clinical judgment and put
residents at risk
(Smith et al., 1998).Slide9
Drug Diversion: Staff Indicators
Staff Behavioral
Indicators
:Frequently volunteers to work extra shifts “could be your best employee”Work the heavier care halls with the “better drugs”
Offer to work weekends, evening, nights when management is not around
Frequent, unexplained disappearances during shift
Feels the need to order the medication and go after the medication.Slide10
Drug Diversion: Staff Indicators Continued
Control medication only needed when that staff person works.
Often shows up on days off to finish work or retrieve forgotten items
Frequently spills or wastes narcotics
Chaotic home/personal life
Refuses to comply with narcotic diversion investigational procedures
Implausible excuses for behavior or become defensiveSlide11
Drug Diversion
Resident Care
Indicators
:Inconsistent or incorrect charting: Narcotic sheet documentation does not match PRN sheet documentation for number of doses administered.
Displays
inconsistent work quality with times of high and low
efficiency
Offers
to medicate other nurses’ patients on a regular basisSlide12
Drug DiversionResident Care Indicators
Care for specific residents
with cognitive impairment
His/her residents reveal consistent pain scale patterns or complain that narcotics are not effective on that shift.Slide13
Preventing Drug Diversion: Best Practices
Policies, Procedures and Controls
Procurement
Storage/SecurityPrescribingPreparation/Administration of CDSHandling WasteDocumentation
Followup
if diversion is suspected.Slide14
Procurement:
Prescriber or physician agent calls pharmacy with order
Hard copy of control drug is written
Electronic copy of control drug is sent to the pharmacyStorage/Security:
Control medications should be stored separately from other medications and under double lock
Access to medication carts/medication cabinets should be limited to person passing medication and wellness director. Don’t hand over medication keys to anyone during shift.
Where are medication carts kept when not in use?
Preventing Drug Diversion: Best PracticesSlide15
Preventing Drug Diversion: Best Practices
Handling Waste:
Waste should have a documented witness
Documentation:Documentation should occur when administering not at the end of a shift.
Documentation should occur on the MAR and medication count sheet
Document pain scores at the time of administration of pain medication
See it-report it!
Report discrepancies immediately
Report suspected diversion
Report inappropriate access to control medication areaSlide16
Preventing Drug Diversion: Best Practices
Managers
:
Use proactive approach for early detection/intervention- Be observed doing documentation audits Med pass observations
Med cart audits randomly
Are carts kept where they are supposed to be kept when not in use?
Are they locked at all times when out of eyesight of the person passing medications?Slide17
Preventing Drug Diversion: Best Practices
Disposing of control substances:
Controlled substance receipt/reconciliation
Timely identification and removal of medicationIdentification of storage method for medication awaiting final disposition
Control and accountability of medications awaiting final disposition
Documentation of actual disposition of medication
Method of destruction consistent with community policy
Procedures for discrepancies, theft/lossSlide18
When Diversion Occurs…CREATE A CHECKLIST TO INCLUDE:
1. Date/Time/Brief description of the event
2. Who is notified-Administrator/DON? What is policy for
timely notification? At that time or Monday AM?Discrepancy report-what is missing? Medication supply/cart inspection. Suggest not only cart that count is off but all controlled
drug storage areas including discontinued medications.
Review documentation of administration vs. count sheetSlide19
CHECKLIST FOR INVESTIGATIONCREATE A CHECKLIST TO INCLUDE:
Review of pain monitor documentation
Review of ordered CDS for trends in frequency and
quantities. Multiple incidents of same person ordering/receiving?8. Are there missing count sheets?
9. Were the controls in refrigerator checked?
10. Are there VA medications not counted every shift?
11. Camera documentation? Blind spots?Slide20
CHECKLIST FOR INVESTIGATION
You should consider contacting the Pharmacy
-
Records of dispensing new and refill control substances for designated time frameCopies of refill requests-who is requesting refills?Delivery manifest of narcotics-who signed for the control medicationsSlide21
CHECKLIST FOR INVESTIGATION
WHO DO WE NOTIFY?
Administrator/Director of Nurses
PoliceOSDH-misappropriation of resident propertyOSDH-Neglect/AbuseNurse Aide Registry (CMAs)Board of Nursing (RN,LPN)
OSDH will notify the Attorney General’s officeSlide22
PROPOSED CHANGES TO PREVENT DIVERSION
Control
substance
medications are required to be ordered electronically January 1, 2020. Many of physicians serving our communities are currently using a software called Sure Scripts to do this.Possible limits to days supply of control medications by insurance companies.Possible early refill limits-90% used prior refill Slide23
PROPOSED CHANGES TO PREVENT DIVERSION
Oklahoma Health Care Authority is looking at incorporating
MME (Morphine Equivalents) for all opioids into the OK Medicaid Management System. Members aggregate MME/day will be included in claims. The CDC encourages caution in doses exceeding 50MME/day.
Some states have changed the requirements for drug disposition to occur within 5 days after drug is discontinued to help prevent diversion (Ohio). Suggest look at what your community policy for destruction is and determine if adequate.Slide24
Medical MarijuanaSlide25
Classification of Schedule I Drugs
Schedule I Controlled Substances
Federal Level:
No currently accepted medical use in the United States
Lack
of accepted safety for use under medical
supervision
High
potential for
abuse
Schedule
I
: heroin, LSD, marijuana, peyote, ecstasy
State Level: Varies by state, 30 states have approved to date
Physicians cannot ‘prescribe’ medical cannabis because prescriptions are regulated under the CSA
Physicians can ‘recommend’ or ‘certify’Slide26
Maryland Health Dept Action April 2018 Slide27
New York Department of Health Oct 2017Emergency Regulations allow Nursing
H
omes and Assisted Living Residences to be among the “designated caregiver facilities” under the state medical marijuana program.
Such facilities may see DOH approval to become a registered designated caregiver for a certified patient in the medical marijuana program.Finally, the regulation also clarified that designated caregivers, including employees of designated caregiver facilities, are protected against arrest, prosecution, penalty, or disciplinary action by professional licensing board or bureau.Slide28
Medical Cannabanoids Legal Under Federal Law
FDA Approved
Marinol (Dronabinol)- THC (N/V, Anorexia)
Cesamet (Nabilone)- THC analog (N/V)Awaiting NDA SubmissionEpidiolex (Cannabidiol)-
Cannabidiol/CBD (Seizures)
Sativex (Nabiximols)- THC+
CBD (Pain, spasms in MS)Slide29
CBD Oil?
OK Health Department Comments
DEA 21 CFR Part 1308 Federal Register/Volume 81, No 240/90194-12/14/16Slide30
REASONS TO ADDRESS DIVERSION NOW
Security of our facilities, staff
and residents!Our residents deserve to receive their prescribed medications and have their health conditions treated appropriately. Slide31
Thank You Slide32
References1.
Narcotic
Use and Diversion in Nursing
Mandy L. Hrobak, University of Arizona College of Nursinghttp://juns.nursing.arizona.edu/articles/Fall%202002/hrobak.htm.2. Nurse Drug Diversion and Nursing Leader's Responsibilities: Legal, Regulatory, Ethical, Humanistic, and Practical Considerations. Tanga, H. JONA's
Healthcare Law, Ethics, and
Regulation Jan 2011 Vol 13(1) pg 13 –16.
http://www.nursingcenter.com/lnc/static?pageid=1193263
.
3.
Impaired healthcare
professional
Marie R. Baldisseri, MD, FCCM
. Crit Care Med 2007 Vol. 35, No. 2 (Suppl.) http://www.csam-asam.org/sites/default/files/pdf/misc/16_article_Baldisseri_Impaired_healthcare_prof_2007.pdf.4.
A Multidisciplinary Approach to Proactive Drug Diversion Prevention. Jerry Siegel Pharm.D. FASHP The Ohio State University Medical
Center Columbus
,
Ohio, 2009.