Deepika Nayyar, PharmD, MBA, BCPS, network pharmacy manager for quality, regulatory compliance, and accreditation at Hackensack Meridian Health, explains that diversion surveillance software alone is not sufficient to prevent drug diversion. She emphasizes the importance of multidisciplinary auditing practices, procurement checks, and dispensing reconciliation processes to catch what technology and artificial intelligence may miss.
Hackensack Meridian Health uses a combination of these methods to monitor and audit its processes, including regular auditing of every single process and routine examination of specific trends that rise to a level where a closer look is needed.
Nayyar notes that they conduct regular auditing and have an approach to monitoring that includes using drug diversion surveillance programs, but also looking at the picture as a whole and considering factors that may not be caught by software alone.
For example, if a user is diverting drugs, they may document pain scores higher on a specific patient when pre- and post- this user, the pain scores were lower, which may not be caught by the surveillance program.
Nayyar emphasizes the importance of having a multidisciplinary approach, including having the patient as part of the team, to ensure that all aspects of the process are being monitored and audited.
They also have procedures in place on the procurement side, including having two people look at the order before it is signed, and having multiple people ensure that what was ordered is what was put in the stock.
Additionally, they look at monthly, weekly, and daily reports to ensure that the math matches up, and continue regular monitoring to prevent diversion.
Nayyar notes that the administration dispensing side also has math that must add up, and that they continue regular monitoring to ensure that everything is in order.
The reporting requirements for suspected diversion vary from state to state, but federally, the DEA requires institutions to report any significant loss, drug theft, or suspicious drug activity within 45 days.
Local DEAs must be informed within 1 day, and states may require Department of Health reporting, board of pharmacy reporting, licensing reporting, or law enforcement reporting, depending on the state and its laws.
Nayyar emphasizes the importance of being aware of these reporting requirements and having policies and processes in place to ensure compliance, including drug diversion surveillance programs.
Nayyar believes that AI-driven surveillance can help institutions move from retrospective, transaction-level review toward more proactive, risk-based detection, and can help identify subtle patterns that may not be caught manually.
However, she notes that AI should not replace clinical judgment, but rather enhance the process, and that having policies and processes in place, including network governance and organizational governance, is essential to preventing diversion.
Hackensack Meridian Health is taking a proactive approach by implementing these measures and continuously monitoring and auditing its processes to prevent drug diversion, which can be supported by remote monitoring tools.
Nayyar’s institution is committed to preventing diversion.
