[Original publication date 7/5/2024] Diversion management starts before a new staff member walks in the door. It is looking for red flags, even before any access to medications is given. It starts before any staff is hired and can be before an interview is offered. Most hiring managers assume that the human resources team is doing their due diligence to monitor for potential issues that may arise, but without asking questions and knowing the process, it is possible that expectations do not meet reality. In addition, we assume that licensing boards are also watching for possible risk factors, but many of us have not reviewed the business and professions code related to licensing and possible loss of license, which may not factor in every misdemeanor charge.

To start from the beginning means that the pharmacy diversion lead needs to meet with human resources to define a set guideline for onboarding any new employee. This information should be shared with your diversion committee or group, and guidelines should be created for screening new hires. This includes “deal breakers,” for example a Driving Under the Influence (DUI) or other charge related to alcohol, illegal, or dangerous drugs within the last 3 years, regardless of felony or misdemeanor status.

This may also mean training human resources staff on how to properly review a professional license, including any public documents and the charges to the applicant by the board. Knowing the issue and the timeline of events better allows the hiring manager to make an educated decision on hiring, and/or can allow the diversion team to better monitor those at a higher risk. For example, a recent hire had public documents about past diversion and substance abuse treatment at a prior facility. This was not discovered until possible diversion occurred at the current facility. The knowledge of the past diversion would have helped decrease the risk to the new institution, the staff member, and most importantly the patients he was treating.

If the decision is made to hire a licensed staff member, prior to giving them access to automated dispensing machine (ADM), the system access request should require the staff member to acknowledge their risk of diversion. This includes asking questions regarding past infractions, but also asking about any current or pending investigations at previous facilities and/or within other localities or states. It is also important to identify the system access request form as a legal document, so that should a new staff member choose to put inaccurate information on the form, termination can be considered.

The system access request form allows the diversion team and the pharmacy informatics team to capture individuals at high risk who may have not been identified by human resources. For example, an employee may have been hired but while waiting to be onboarded was arrested for a DUI, or an employee recently left an institution after being placed under investigation for diversion but with a licensing board that is only starting the investigation process.

In summary, diversion management is not just what is occurring within the walls of the institution. It starts when a person applies to your facility. It is critical to research all avenues for areas of concern, and to ask important questions and understand the current licensing and onboarding process. It is every member of the team’s responsibility to ensure that the staff, facility, and patients are at the lowest risk possible.