Kimberly New, RN, JD, founder of Diversion Specialists in Knoxville, TN, who frequently consults with healthcare facilities on drug diversion, cites the following common areas of weakness in diversion prevention programs:

  • Lack of internal controls over controlled substances stored in emergency kits for trauma or urgent needs.
  • Pain response documentation not regularly reviewed for patterns.
  • Inadequate segregation of duties.
  • End user passwords not changed per hospital policy.
  • End users not terminated from system after job changes/responsibilities, termination.
  • Discharged patient list remaining available for hours after discharge.
  • Drug testing not done at pre-employment screening; drug testing not performed randomly for staff with drug access.
  • Staff with little or no training/competency on system (poor practices).
  • Built-in system controls “turned off”— too cumbersome.1

Signs of HCW diversion/impairment:

  • Tardiness, unscheduled absences and an excessive number of sick days used.
  • Frequent disappearances from the work site and taking frequent or long trips to the bathroom or to the stockroom where drugs are kept.
  • Volunteers for overtime and is at work when not scheduled to be there.
  • Arrives at work early and stays late.
  • Pattern of removal of controlled substances near or at end of shift.
  • Work performance alternates between periods of high and low productivity, may suffer from mistakes, poor judgment, and bad decisions.
  • Interpersonal relations with colleagues, staff, and patients suffer. Rarely admits errors or accepts blame for errors or oversights (denial).
  • Insistence on personal administration of injected narcotics to patients.
  • Heavy or no “wastage” of drugs.
  • Pattern of holding waste until oncoming shift.

CDC prevention tips:2

  • Prepare medications as close as possible to the time of administration.
  • Properly label pre-drawn syringes to include patient name.
  • Consider use of tamper-resistant and tamper-evident syringes and automated dispensing cabinets with security and tracking features.
  • Conduct audits by pharmacy staff, with testing to verify the identity or concentration of unused drugs that are returned to the pharmacy or discarded by healthcare workers.


  1. New KS, Loya KC. Health Facility Drug Diversion: Essential Compliance & Auditing Measures. Slide presentation, 2013.
  2. Schaefer, M.K., Perz, J.F. Outbreaks of infections associated with drug diversion by US health care personnel. Mayo Clin Proc 2014;89:878–887.