Prescription Drug Theft & Pharmacy Security
America
is addicted more to pharmaceuticals than street drugs
and 12% - 16% of all health care professionals are
estimated to be addicted at some point during their
career.
Click here if you wish to make a
confidential inquiry about a problem you are
experiencing.
I can
assist with loss prevention and operational areas such
as:
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Controlled drug theft and diversion investigations.
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Pharmacy
physical security.
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Robbery prevention planning.
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Pharmacy shrink.
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Prescription drug fraud and manipulation of computerized
dispensing systems
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Legend drug theft and diversion.
Whether you are a small retail pharmacy, a hospital,
nursing home, or even a medical first responder, we
can assist in strengthening accountability thus
reducing exposure to the DEA and State Board of
Pharmacy audits. Let us also help with any
investigative needs or pharmacy audits of operational
stability. We also clearly understand the dilemma of
an impaired employee and therefore understand the need
for discretion in handling these issues.
Also read
Prosecuting Employee Theft and
the
Employee Theft Guide.
Drug Diversion:
Insight Into Solutions
Drug impairment and, more seriously, drug diversion is
highly prevalent in the healthcare industry. Both
contain a high degree of exposure to licenses,
continuation of business, criminal records and
unwanted notoriety. While both follow the same
behavior, the final resolution process is vastly
different.
Drug theft, whether for personal use or for sale on
the street, is a serious threat to any healthcare
provider. The continuing rise of illicit prescription
drug use by high school and college aged students is
alarming. Regardless of the intent of the end user,
this topic involves such a wide spectrum of
personnel and business types that prevention,
investigation, and resolution takes a great deal of
skill. This skill requires knowledge of business
practices, shrinkage, State and Federal regulatory
law, criminal law, rehabilitation consideration and
employment law. It is a complicated matter.
Let's separate impairment from diversion. Impairment,
or addiction, involves the theft of mostly narcotics
for personal use. Theft of steroids and non
controlled drugs such as Soma would also fall into
this category. Diversion is the theft of any
pharmaceutical to be sold or traded for personal
gain. Resale is not limited to common "street crime"
but also can involve Medicare fraud, theft for other
providers, organized crime and a host of others.
Theft of high dollar HIV/AIDS medications, steroids,
birth control pills, and analgesics are quite common
place. Regardless of the basis or type of theft, the
implications are far reaching.
Detection
Detection of small amounts theft over long periods of
time is difficult but not impossible. Detection of
large, organized theft is should be more easily
identified but in many cases the person controlling
the inventory is committing the theft. This
supervising individual whether a nurse, pharmacist,
mail order manager, doctor or dentist has the
opportunity and the means to both order and cover
losses. It is a sophisticated crime.
How can theft be detected? No matter how crafty the
suspect, the one element that cannot be controlled by
those engaged in theft is the financial performance of
their operation. This is not the case with a self
operated business but those types of thefts are
primarily discovered through audits by law
enforcement. Detection is a by product of security.
Let's look at detection.
In
its simplest form, detection of the loss of
pharmaceuticals is a basic inventory control
function. The three variables are replenishment,
documented usage, replenishment. Regardless of the
type of business there is a certain amount of anything
that is in inventory: books, parts, computers,
supplies, drugs. During some period of time some of
that starting inventory, either in dollars or physical
units, is used. That usage is generally tracked by
tick marks on a note pad to a highly sophisticated
mechanized program that has automatic order points.
Regardless, depletion of inventory is fairly
predictable over time and can therefore be forecast as
well. Here is a common sense, simplistic example of
monitoring inventory: You order what you use. There
is no reason to order anything more than at the rate
you use it and by using percentages of increase, the
variances become highly recognizable. Use percentages
because in drug inventories, units may not raise a
flag.
Let's use Drug X (not its generic equivalents) as an
example. Over the past several months seven bottles
of X are ordered each month and random audits show
five bottles dispensed each month during the same time
frame. Further examination reveals approximately 2
bottles on the shelf. History tells you that 5
dispensed bottles is very predictable. Ordering
begins to gradually increase from 7 to 9 to 12 bottles
per month. An increase of 5 bottles per month would
be lost within a large inventory system. An increase
in ordering of Drug X of 60% would raise a flag. If
dispensing/sales/transfers, etc increased 60%, it
would explain the increase in orders. However, with
maintaining a recorded distribution of only the same 5
units would mean, in theory that the remaining units
should be accounted for. Generally there is no
explanation and the investigation begins.
Replenishment and dispensing/sales are on parallel
lines that obviously move together. Movement of
replenishment without movement of dispensed should
initiate review. This evaluation can also be done in
reverse where a previous discrepancy suddenly
stopped. Who or what caused the activity to stop?
Theft activity of individual units, such as pills,
will have the same effect but over a longer period of
time because the stolen drugs still have to be
replaced in some way.
Prevention
and Awareness
Theft
of most anything revolves around the same general
factors: Need, Opportunity, Justification. Drugs add
a fourth dynamic, addiction. Prevention then becomes
more difficult because the illness of addiction allows
a person to take risks that others would not take. In
that case, prevention and detection must work hand in
hand. Physical security measures will only deter the
opportunist, not the person with the keys! Prevention
programs should be driven to the 80-90% of personnel
who would never participate in drug theft. Successful
prevention and awareness programs are not an "event"
to be held annually only to die two months later.
Prevention is also a byproduct of detection. High
probability of detection is a good deterrent. The
fact that audit and review programs exist should be a
part of any theft prevention program. This requires
an intensive review of all operational procedures and
practices to ensure that all appropriate measures are
in place and that compliance is consistent. To
reiterate however, prevention and awareness campaigns
will do little to curb theft by those impaired or
those who are making significant income from sales.
Detection then becomes primary.
A
primary facet to any prevention program begins with
the hiring process. Full criminal background checks
should be mandatory for any level of employee who has
access to drugs. Preemployment and random drug
testing is still highly controversial in many circles
of health care. This should be considered with a high
degree of care but has long term benefits that should
not be overlooked.
