Sometimes being a good manager means being part detective. If you feel a little like Sherlock Holmes some days, you're not alone! Especially when it comes to preventing and battling drug diversion in the surgical setting. I'm constantly working with clients to prevent diversion. Today I'm going to share my BEST weapon in the anti-diversion arsenal... auditing.
DEA 222 FORMS DEA 222 forms should be kept secure and unsigned. When CII orders need to be placed, the registrant or an authorized manager should receive a single 222 form, record the serial number of the form, have it filled out, and then finally have it signed by the registrant or power of attorney. Once the purchase is made and the drugs are received, the packing slip should be checked against the 222 form. As long as the packing slip and 222 form are correct, staple the two together and file. These should be kept for no less than 2 years in a readily retrievable location .
THE WHOLESALER REPORT Did you know that your wholesaler can provide you with a full purchasing report of all your controlled substances, for a specific period of time? For example, if you'd like to audit the amount of controlled substances signed into your inventory for February, 2019, your wholesaler can provide a report of all the drugs you received in that month. Even if you're already tracking receipt of controlled substances purchased via DEA 222 form or CSOS, that doesn't account for your CIII-CV drugs being received. Performing this audit ensures that when the drugs arrive at your facility, they're actually making it into your narcotic cabinet. This audit is especially useful in centers with few staff members. If the same individual manages stock, purchases, unpacks, and inventories all the controlled substances, auditing controlled substance purchases this way alleviates any burden or liability from that individual in the event of missing controlled substances. In this instance, a manager or separate individual should perform the audit.
CHART AUDIT In a given month, how many different staff members provide care for your patients? How many of them have access to controlled substances during the course of care? Hypothetically you should be able to trace the "life" of the controlled substance from inventory in the narcotic cabinet, to sign-out, to administration, to wastage (if applicable). Perform a random chart audit comparing the administration of controlled substances to the narcotic anesthesia sheets (or inventory sheet depending on your policy). This is an excellent exercise to promote compliant documentation, at the very least.