Preventing Drug Diversion in Pharmacy Settings: Best Practices, DEA Regulations, and Comprehensive Security Strategies

In an interview with Pharmacy Times®, Matthew Piskun, PharmD, MBA, vice president of ambulatory and surgical services at Shore Medical Center, discussed the critical issue of drug diversion in pharmacy settings, highlighting his presentation at the 2025 New Jersey Society of Health-System Pharmacists (NJSHP) Annual Meeting.

Piskun shares the importance of limiting access to controlled substances and implementing rigorous inventory management practices. He emphasized the need for regular audits, staff training, and comprehensive documentation to prevent theft and ensure patient safety. The discussion covered DEA regulations, including the requirement to report theft within 24 hours and conduct biannual narcotic inventories. Piskun recommended a multidisciplinary approach involving pharmacy, security, nursing, and risk management to effectively monitor and address potential drug diversion incidents.

Pharmacy Times: Can you describe some of the common reasons why drug diversion occurs within a pharmacy setting, and what are the potential consequences for patient safety, public health, and pharmacy staff involved?

Matthew Piskun, PharmD, MBA: Ignoring the socioeconomic reasons that individuals get addicted and steal, the most common causes are just allowing for the opportunities and not shoring up all the holes that might be in your practice. For example, you really need to limit who has access to, handles, stores, and orders your controlled substances. Maybe you're not doing enough audits, not having a policy to address and resolve discrepancies very quickly, as well as not having maybe a monitoring or auditing system. For example, like a third-party application that tracks and trends. Diversion in the workplace can have significant effects on patient care; specifically, if you're diverting pain medication that's due for them, they could potentially be in pain — not to mention employees who may be impaired on the job. Then if these happen to involve a sterile product, then you're dealing with a whole new issue where the Department of Health would get involved. It may require patient testing for bloodborne pathogens like hepatitis B, C, and HIV. I have seen that happen, and it's not good when it does.

Pharmacy Times: What are some key legal and regulatory requirements, particularly those from the DEA, that pharmacies must adhere to in order to prevent drug diversion?

Piskun: The DEA does require the reporting of theft or loss within 24 hours upon discovery of the theft or loss, and you need to use a DEA 106 form. Also, it's a federal guideline to do your biannual narcotic inventory for all your controlled drug substances. They require pharmacies to keep very accurate controlled drug substance records. They have language that states that you need to allow for maintaining accurate records and accountability, as well as effective controls and procedures to guard against theft, which is very vague regulation, but it's there.

Pharmacy Times: Could you outline some best practices for inventory control and documentation that help to minimize the risk of drug diversion in a pharmacy?

Piskun: Well, you can limit who can buy and deliver narcotics. These days you can buy them electronically, and the more people you give access to, the less control you have over trying to get them done. Limit access to your storage areas and access points, and only store controlled substances where you keep your controlled drug substances. We had a situation in my institution where they used to keep employee paychecks in the narcotic station, and then that allowed for people to go in there for non-narcotic reasons. Good things are not ahead if you do that. You should do audits, but you should rotate who does them. You don't want the same employee doing the same cabinet over and over again. It should be random and set up that way so that people are checking on other people. Even though the regulations say you should do a biannual inventory, I would recommend that you do it much more frequently. We do it annually. I have colleagues that do it every 6 months. That's a little too labor-intensive for us, but doing it more than biannually is one key thing that I think would be helpful. Also, you just need to resolve discrepancies as soon as possible when you see that they occur.

Pharmacy Times: In what ways can comprehensive staff training contribute to preventing drug diversion and ensuring compliance with relevant regulations and security protocols?

Piskun: One of the things that we had to do in my institution was really train people to understand the extreme importance of these medications when it comes to ordering, restocking, and counting them. They're not like blood pressure tablets or cholesterol tablets. They're very significant regulatory-wise to keep track of every single one, so you really need to hammer that home. Also, we have scanning on restock. So, scanning what you're putting in there and counting, making sure that the right thing is going in, because if you have an incorrect count and you have things that are in the wrong pocket in the automated dispensing cabinet, that makes it a lot harder to resolve. So, correct count, correct place, scanning, and learning how to troubleshoot discrepancies. That includes a lot of things — learning how to run reports for nursing, learning how to interpret the reports, and over time learning all the different things that may have happened to help resolve those things. Of course, a lot of that falls on the leadership of the department. The leadership has to take full accountability for controlled drug substances, and that needs to trickle downward all the way down to the pharmacy technician that might be delivering these meds.

Pharmacy Times: Is there anything you would like to add?

Piskun: There are a couple of best practices that I think would be helpful, especially if you ever find the DEA at your place of work. When you do your controlled substance inventory, and again, ideally, that would be more than every 2 years; you would do it more frequently. I would run at that time your purchasing records, your usage records, as well as the individual inventory that is out on the floors in the automated dispensing cabinet. This way, you have a snapshot of every single thing in time should there be an issue after that. Another thing that's really good to do is have a multidisciplinary team that looks at each and every diversion. That will include your infection control practitioners, nursing, risk management, pharmacy, and security, especially. Security plays a huge role when it comes to pharmacy doors and all the way down to seeing when people badge into certain areas, as well as camera placement and reported footage. Those are a couple of things that I would recommend.