by Melissa Brentlinger and Greg Burger
This is our third Point of View in our series on drug diversion topics. We have already covered the importance of culture and monitoring in the first two articles and now we will discuss segregation of duties. Pharmacies themselves are especially vulnerable because of the degree of access its employees have to inventory. An area of drug diversion that pharmacies tend to overlook is the segregation of the buying and receiving duties.
Oftentimes, pharmacies combine these roles to create one job title for a full-time employee. For some hospitals there isn’t enough work to justify dedicating one person to either buyer or receiver and defending the reasoning for the difference in pay (if there is one) from the rest of the staff. What pharmacies fail to realize is the consequence of having only one employee responsible for both. This not only opens up the pharmacy to potential theft, it also fails to protect that employee from accusations. In a recent California court case (Sternberg v. California State Board of Pharmacy) a pharmacist-in-charge is being held liable for drug theft by a technician due to their responsibility for record keeping and drug security. The technician had stolen at least 216,630 tablets of Norco® over the course of a few years by manipulating purchases, receiving documents and records.1 In still another incident, at the Salt Lake VA Hospital, a pharmacy supervisor is suspected of stealing more than 24,000 painkillers and 25 vials of testosterone over five years.2 State and Federal authorities have been investigating this criminal activity for 12 months now.
If the two previous examples weren’t enough to catch your attention, Emory University Hospital Midtown was just sanctioned with a $200,000 fine and had its pharmacy license placed on probation for 3 years by the Georgia Board of Pharmacy as part of a consent order. Two pharmacy technicians purportedly diverted more than 1 million doses of controlled substances from October 2008 until July 2013, according to The Augusta Chronicle.3 According to the Chronicle’s article “The scheme was perpetuated through coordinated illicit activity, including misappropriating credentials from a pharmacy buyer; exploiting use of an electronic function in the [hospital’s] system to conceal the unauthorized purchases, and bypassing the receiving/inventorying process.” Many drug diversion programs focus on nursing personnel but these incidents highlight the need for increased scrutiny and segregation of duties with appropriate checks and balances in pharmacy.
Many pharmacies utilize a pharmacist to receive and check scheduled drugs against the manifests and then place them in their designated secure location. It is important to note that scheduled drugs are not the only products diverted. One example of this is Narcan, now commonly in the news for reversing a heroin overdose. You can imagine what the street value of this product could be to a heroin addict that would like to have Narcan® on hand to avoid issues with law enforcement should an overdose occur. Another example is ephedrine and pseudoephedrine used in Methamphetamine manufacturing. While most might imagine large quantities disappearing for labs producing bulk, in reality someone’s own personal lab might take very little product. Most people do not even consider what these two products could be used for, making the ease of diverting these products even easier.
Virtually any prescription product may be subject to diversion for personal use or financial gain. Expensive antibiotics, inhalers, anesthetic gases and propofol are all possible targets among others. The question to ask is have you done a risk assessment and what mechanisms are in place to deter diversion. Separation of duties is an easy place to start.
An extra set of eyes on what is being ordered and received makes another person aware of what is coming into the pharmacy. Employers sometimes fail to realize how easy it is for a buyer to order something without their knowledge and then divert the product during the receiving process without appropriate check and balances. This is especially true for those non-formulary products that are only ordered for a specific patient, are kept in a different area of the pharmacy, and are left outside a pharmacy’s general inventory tracking system if there is one.
Another good reason to segregate these job roles is because of all the products that are currently on manufacturer backorder. Backordered products have become such an ongoing issue that pharmacy employees have conditioned themselves not to expect a complete order. If only one person is doing both the buying and receiving it could go without question that an employee would miss the difference between a product being diverted and one who’s ordered quantity was not completely filled due to a shortage.
Segregating the buyer and receiver duties does not have to be overly complicated, nor does it have to involve hiring extra staff. While a buyer’s duties should be limited to very few employees, receiving duties do not need to be. Any employee should be able to match product to manifest. Employees can be rotated through and if you have more than one employee receiving, the faster it gets done. A buyers duties can vary and be wide-ranging. Separating the receiving duties from them may actually give more time and opportunity to focus other priorities.
Drug diversion can happen at all levels in the organization. Starting at ordering and receiving when a product enters the pharmacy is a good start to prevention. Heightened awareness and sound business principles will aid prevention efforts and protect the innocent.
1MRoss, “5 Court Cases Involving Pharmacists”, Pharmacy Times, March 6, 2016.
2DChen, “Federal authorities investigating large drug theft at VA Hospital”, Salt Lake Tribune, March 9, 2016.
3AMiller, “Emory Hospital reports large scale drug thefts”, Augusta Chronical, March 8, 2016.