Compliance: Diversion-Prevention program

 

Compliance Perspective

Issue Nursing home employees may be involved in drug-related activities, which can lead to legal and ethical issues. The use, possession, sale, transfer, or distribution of non-medically prescribed controlled substances or of alcohol on the facility’s premises or at any of the facility’s work sites should be prohibited. Any employee found in violation should be subject to disciplinary action up to and including dismissal on the first offense. Employees should be prohibited from possessing paraphernalia on facility premises used in connection with non-medically prescribed controlled substances and from reporting to and being at work while under the influence of alcohol, illegal drugs, or any controlled substance. Failure to prevent diversion of residents’ prescribed controlled medications by staff who sell or take the drugs for their personal use may be considered abuse, neglect, misappropriation, and fraud, in violation of state and federal regulations. Facilities should implement a proactive diversion-prevention program which identifies the types of medications most likely to be taken, signs that diversion has taken place, and signs of impairment. Discussion Points Facilities should have policies and procedures prohibiting drug and alcohol use at work, and all employees should read and sign an agreement stating they understand and will comply with these policies. Policies should also include guidelines for handling medications, reporting suspicious activities, and conducting background checks on employees. Staff should receive regular training on drug-related issues. This training should cover topics such as recognizing drug-related activities, reporting suspicious activities, and handling medications. A program titled Drug and Alcohol Policy and Practices is available to all clients on Med-Net Academy in the Substance Use category.  Periodically audit to ensure that nursing home employees are following policies and procedures addressing drug-related activities. These audits should include reviews of medication logs, employee background checks, and reports of suspicious activities.