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Veterinary Drug Diversion Solutions
1.
2. “’Drug diversion’ is best defined as the diversion of licit
drugs for illicit purposes. It involves the diversion of drugs
from legal and medically necessary uses towards uses that
are illegal and typically not medically authorized or
necessary.”
Source: “Drug Diversion in the Medicaid Program: State Strategies for Reducing Prescription Drug Diversion in Medicaid,”
Centers for Medicare & Medicaid
Services (Baltimore, MD: January 2012), p. 1
https://www.cms.gov/Medicare-Medicaid-Coordination/Fraud- Prevention/MedicaidIntegrityProgram/
downloads/drugdiversion.pdf
3. “The estimated cost of diversion and abuse to public and private
medical insurers is approximately $72.5 billion a year, much of which
is passed to consumers through higher health insurance premiums.
Additionally, the abuse of prescription opioids is burdening the budgets
of substance abuse treatment providers, particularly as prescription
opioid abuse might be fueling heroin abuse rates in some areas of the
United States.”
Source: National Drug Intelligence Center, Drug Enforcement Administration, “National Prescription Drug Threat Assessment,” (Washington DC, April 2009),
http://www.justice.gov/archive/ndic/pubs33/33775/33775p.pdf
4. The current opioid epidemic is punishing every socio-
economic sector in the United States.
Each year more healthcare employees are caught
abusing or are dependent on prescription drugs, putting
patient care at risk.
The crisis in the United States is driven, in part, by
indiscriminate prescribing and other criminal activity.
Federal and state investigation of controlled substance
diversion has increased at a feverish pace, with civil fines
levied against individuals and institutions across almost
every segment of the healthcare industry, including
veterinary facilities.
5. Veterinarians and their staffs have access to a large variety of mind-
altering, potentially addictive drugs, including controlled as well as non-
controlled substances which are highly addictive.
• Naloxone
• Propofol
• Dexmedetomidine
• Gabapentin
• Amantadine
• Trazodone
• Fentanyl
• Morphine
• Hydromorphone
• Oxymorphone
• Buprenorphine
• Butorphanol
• Phenobarbital
• Pentobarbital
• Euthanasia solution
• Ketamine
• Diazepam
• Midazolam
• Alfaxalone
• Tramadol
• Tiletamine-zolazepam (Telazol)
ControlledSubstances
UncontrolledSubstances
9. Every company and practitioner buying,
dispensing, prescribing, and administering
controlled substances is at risk!
Trinity Pharmacy in
Carrollton,Texas, and one
of its owners, Jonathan
Paul Lipe, paid the United
States $400,000 to settle
alleged violations of the
Controlled Substances Act
in the Eastern District of
Texas.
Veterinarian Michael
Paul Good, owner of
Town & Country
Veterinary Clinic paid a
civil settlement of
$90,000 to resolve
allegations that he failed
to meet the mandatory
recordkeeping
requirements of the
Controlled Substances
Act.
McKesson, the nation’s
largest distributor of
controlled substances,
must pay $150 million in
fines in a case of lax
recordkeeping, failed
due diligence, and poor
prevention of potential
diversion of controlled
substances.
10. Pharmaceutical diversion is generally thought of as only
affecting human practitioners (i.e., patients and
physicians, dentists, nurses, etc.). But pet owners who
divert pharmaceuticals are now part of the problem.
Because veterinarians prescribe virtually any
prescription drug, diverters seeking anything from pain
relievers to benzodiazepines may target your practice.
“Doctor shopping is a substantial problem for veterinary clinics,
and the DEA is tracking reports. Veterinarians also have to
deal with theft and misuse by employees, burglary, and
possibly robbery.”
- Barbara L. Carreno, a spokeswoman for the Drug Enforcement
Administration
11. “A dog owner reportedly trained his pooch to cough
on command while being examined by the vet, so
he could get hydrocodone cough medicine.”
- Pharmacy Times
- New York Post
12. Veterinarians and their staff also face well-documented job
stresses as a result of long hours, challenging cases, difficult
clients, economic challenges and the emotional
consequences of performing animal euthanasia.
These stressors create a significant layer of drug abuse risk in
the veterinary workplace in addition to those posed by current
drug users seeking employment in a workplace where
psychoactive drugs are comparatively available.
With minimal internal oversight of the management of
controlled substances, minimal drug testing and background
checks of employees, and manual inventory practices, leave
the profession ripe for diversion activities.
13. A Utah veterinarian paid $200K in civil penalties to resolve
allegations involving the handling of controlled substances
at his business.
A Marietta veterinary practice paid a federal fine of $90K
for failure to maintain accurate recordkeeping of its
controlled substance inventory.
Penalties can range from written warnings to fines, as well as disciplinary
administrative actions (including revocations of state and federal controlled
substance certifications).
14. With government agencies under more pressure to curb America’s
drug problems, health care providers are being targeted for more
frequent audits and reviews by federal and state regulatory agencies.
Even veterinarians who have been “left alone” or who have “never
had a problem” are potential targets for random inspections by the
Drug Enforcement Administration (DEA).
And complaints by employees, ex-spouses, and former clients can
result in investigations….
15. While there are multiple regulations relevant to a veterinarian’s use of
controlled substances, the following are the four most common categories
of violations cited by DEA in veterinary practice operations.
Registration Issues
Lack of Physical
Security
Poor
Recordkeeping
Failure to
Complete
Background
Checks
Each violation carries a possible penalty of $14.5K per infraction
16. Diversion crimes can also expose your practice to other risks.
Loss of
License Damaged
Reputation
17. A 30-year-old Sarasota woman was arrested and charged after she
stole drugs from two veterinary clinics where she worked.
A veterinary technician stole fentanyl, midazolam and diazepam from
Critical Vet Care and Companion Animal Neurology to support her drug
habit
A vet tech stole diazepam tablets and three 10-milliliter vials of
ketamine from the animal hospital where she worked.
A veterinary technician in East Brookfield, Massachusetts was charged
with stealing 7,800 opioid pills and trying to cover her tracks by
changing clinic records.
“Veterinary clinics may increasingly become victims of institutional
diversion, including self-abuse, employee theft and even pet owners
seeking pharmaceutical drugs” – Sarasota County Sheriff’s Office
18. “No other aspect of the veterinary profession possesses
a greater potential for injury and abuse than
medications, especially controlled substances. Because
of this potential, it is essential that each veterinarian
upholds the law and standard of the veterinary
profession in administering, dispensing and prescribing
medication.”
-AVMA PLIT
19. Think your practice doesn’t have a diversion problem? Spend time with the
DEA regulations regarding drug diversion and you may think differently.
You may also lack the automation, advanced training, and
policies/procedures to detect and address diversion.
Is your facility protected?
Is your security/intrusion detection system up to date,
comprehensive, and functional?
Are your recordkeeping procedures current and compliant with
federal/state laws?
Have you completed a biennial inventory and other required
records?
Does your facility complete a background check and drug screening
for each employee?
Do you randomly drug test your employees?
20. You may trust your employees, but experience proves that a culture based
on “trust” and goodwill can implode when it comes to preventing diversion.
TITAN takes tangible, fact-based steps to reduce your exposure to
diversion – and the threat of a government audit.
Audit Analyze Report Remediate Train
21. TITAN offers solutions, guidance, and support covering all aspects of
DEA and state regulatory compliance managed by subject matter
experts who are former DEA Agents and/or Diversion Investigators
to guide you through the process.
By working with a team experienced in all facets of DEA regulatory and
compliance requirements, TITAN will work with you to:
Minimize exposure through active dialogue and training
Reduce the possibility of a negative intrusion
Implement and leverage best practices developed by industry experts
Increase the likelihood of a positive outcome if you do become the victim
of diversion, or are subjected to a government inspection
22. Customized
training and
education program
Facility risk
assessment
Audit (regulatory
document and
procedure review)
policies,
procedures, reports
Investigative
support
Crisis management
TITAN offers a full suite of diversion solutions.
23. Veterinarians, physicians, hospital executives, Fortune 500
companies, and business leaders repeatedly turn to TITAN
when faced with the most sensitive, complex and potentially
damaging investigations.
Having the right plan and having the right partner - before
and after the government comes knocking - can mean the
difference between quiet resolution or ugly public
indictment.
