Drug Diversion Controls. MedStar Mobile Healthcare Best Practices Chad Carr Compliance Officer, Paralegal

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1 Drug Diversion Controls MedStar Mobile Healthcare Best Practices Chad Carr Compliance Officer, Paralegal

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3 Our Journey in Tracking Narcotics

4 Has to Start Somewhere. Process Started on Paper omanual Process for Documenting Transactions omanual Process for Documenting Usage/Waste omanual Process Performing and Documenting Audits

5 We Evolved

6 Paper and Electronic ocreated a SharePoint List for Documenting Transactions omanual Process for Documenting Usage/Waste omanual Process Performing and Documenting Audits

7 Its 2017!!! Electronic otransactions are Captured Electronically ousage/waste Captured Electronically oaudits are Captured Electronically

8 Training Overview of Policies, Procedures and Processes Testing oto Ensure Baseline Knowledge to Accomplish the Process is Intact Training oobjective Based HIPAA odo not Forget the Importance of HIPPA

9 Policies and Procedures Policies are the WhatoWhat you can and cannot do with narcotics Procedures are the How toohow to Perform Transactions, how to administer controlled substances within protocol guidelines, and properly waste. The Process of Performing the ProcedureoStep-by-Step Actions

10 Narcotic Transactions Check-in and/or Check-out overification Provider is authorized to handle narcotics based on credential o Physical Narcotic Inspection Cap is intact Vial is full of fluid at the correct level with all other vials Label has not been compromised Vial has been labeled with a unique Control Number oauthorization Captured by password/pin electronically

11 Reconciliation of Usage Two Part Process odocumentation in epcr by the administering Paramedic omatching Documentation in narcotic tracking platform (Operative IQ) Matching Data Elements oresponse Number oadministering Provider onarcotic odose owaste

12 Logistics Team Physical Shift Reconciliation of Previous Days Usage Weekly Audit with a Medical Director representative.

13 Audit Points Total Vials in the Field Total Vials Not in the Field otwo separate safes oincludes any waste due to damage or expiration until destructed Virtual count in OIQ and physical count must reconcile

14 Best Practices for Compliance Know your processes Work with other internal departments Know the laws Follow a defined process when anomalies occur Have a defined drug testing policy and follow it Trust, but verify Report substance abuse to the DSHS

15 Monthly system wide audits omedstar measures each paramedic's controlled substance use and waste and preforms monthly audits, and compares the numbers to every paramedic in the system. ooutliers. We set the threshold for high use or waste at 3 times the system average.

16 Individual administration / waste patterns Never ignore patterns Monthly controlled substance administration (Provider A vs. system average)

17 Monthly controlled substance waste (Provider B vs. system average)

18 In those cases that are 3 times higher than the system threshold 1. Paramedics have a face-to-face QA reviews with the Medical Director to better understand their critical thinking and clinical decision- making. 2. Cases are also independently reviewed by the Compliance Officer to determine if a drug diversion has occurred.

19 Drug Testing Random For cause/suspicion Return to Duty (Post leave) Any employee who, as indicated by a positive drug or alcohol test, is under the influence of alcohol, or a controlled substances not prescribed to the employee, or High Risk Medications HRM, not reported by the employee prior to the test, shall be deemed in violation of MedStar policy and subject to disciplinary action up to and including separation.

20 Drug Testing Reasonable Suspicion o A belief based on observations sufficient to lead management to suspect the employee is or was under the influence of drugs or alcohol. Narcotic Anomalies o Unusual, excessive use of controlled narcotics o Inappropriate administration of narcotics o Failure to account for or to return issued narcotics o Other anomalies related to narcotics

21 Self-Reporting Vs. Discovery Employees who abuse drugs or who have a dependence on drugs or alcohol may come forward self-report, and request help prior to being selected for drug testing. At such time, MedStar will work with the employee to get help via MedStar s Employee Assistance Program if self reporting.

22 Investigation process and DSHS reporting

23 Look at the fact Review all the data Ask Questions Look for patterns of narcotic use / waste Look for overall performance patterns Look at attendance issues Interview all parties involved in an incident Work with your Medical Director to determine adherence to protocol for usage

24 Don t pass the problem down the road to another unsuspecting Provider. Report it to the DSHS!

25 DSHS Reporting 1. Build a relationship with your DSHS Compliance EMS Specialist 2. Know what to expect if an issue arises 3. Have an action plan in place 4. Report all suspected or determined substance abuse

26 Be prepared to provide the following data to the DSHS within 48 hours from the time you make a report: o A signed and dated statement regarding the incident from all parties o Copy of you current protocols signed by your Medical Director o Letter from your Medical Director about the incident / behavior o Copy of the employees entire personnel file (with pay info redacted) o Drug test results, dates, times, location completed o Employees narcotic use/waste history data for 90 days to 6 months o Interview notes, audio recording, photos o QI/ QA Processes and procedure o Company policies and guidelines

27 Never think you ve seen it all and get comfortable! You might miss something

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