Best practices for diversion control in veterinary practices

Diversion of controlled substances is a real risk for veterinary practices, and addressing it requires vigilance, proper procedures, and staff education. A single weak spot in your protocols can lead to significant regulatory, financial, and reputational consequences. In this Q&A, Krista Tongring, President, DEA Compliance, Guidepost Solutions, provides insight into how veterinary practices can protect themselves from diversion risks, prepare for inspections, and establish a culture of accountability. 

The views expressed are Krista’s own and do not constitute an endorsement of any product.

What are some opportunities for diversion of controlled substances within a veterinary practice? 

Krista Tongring: Diversion can occur in several ways, often exploiting gaps in oversight or documentation. One common method involves tampering with liquid medications. People will pull substances out of a vial in a syringe for their own use and then refill the vial with saline. This tactic makes it appear as though the vial is still full when, in reality, it has been altered. 

Another opportunity for diversion arises during the ordering and receiving processes. If the same person is responsible for both tasks, it becomes easy for them to order more controlled substances than the practice needs and divert the surplus for personal use. Without checks and balances, it’s very difficult to catch this kind of activity. 

Walk us through what happens in an inspection.

Krista Tongring: Inspections are a critical moment for any practice, as they evaluate how well you are complying with regulations. During an inspection, the Drug Enforcement Administration (DEA) will review your policies and procedures for handling controlled substances. They will examine inventory logs, records of what was ordered, what was administered, what was wasted, and what was sent to a reverse distributor. They will want to see that everything zeros out, meaning that the practice’s inventory records must reconcile completely. 

Veterinary practitioners must remain actively involved in compliance efforts. This includes regularly checking inventory, reviewing logbooks, and ensuring proper documentation is maintained. Delegating these responsibilities entirely to someone else in the practice leaves room for potential gaps or oversights. 

What constitutes “failing,” and what are the consequences? 

Krista Tongring: Failing an inspection often comes down to poor recordkeeping. If you don’t have any records whatsoever or if you’re not controlling your prescription pad, that’s a big deal. These issues can lead to DEA actions, which may include fines, restrictions on controlled substance use, or even the suspension of your DEA registration. 

Immediate shutdowns are rare and typically occur only under what’s known as an immediate suspension order. The DEA must go back to headquarters and to the chief counsel’s office to get such an order. While this is not a common outcome, it underscores the seriousness of compliance failures and the importance of addressing any weaknesses before an inspection occurs. 

How can a veterinary practice be more vigilant in their day-to-day operations? 

Krista Tongring: Day-to-day vigilance starts with clear, well-documented policies and procedures. All veterinary practices should have protocols in place that outline how controlled substances are ordered, who is authorized to order them, how they are stored, and how they are removed from inventory. These policies and procedures lay the foundation for compliance, but they must also be followed in practice. 

Regular audits are another critical component. Practices should conduct routine checks to ensure policies are being followed and that records are accurate. Audits can help identify gaps or inconsistencies before they become larger issues. You have to audit to ensure that you are following the policies and procedures.  

What role does staff education play in diversion control? 

Krista Tongring: Staff education is a cornerstone of effective diversion control. Krista recommends involving team members in the creation of policies and procedures to ensure they are realistic and practical for the practice’s operations. You need to work with your staff when creating policies to ensure they are practical for your business. Without input from the team, policies risk being either too cumbersome or too vague, leading to non-compliance. Once policies are finalized, training is critical. 

Comprehensive training ensures that staff understand their roles and responsibilities, reducing the likelihood of accidental errors or intentional diversion. By fostering a culture of education and accountability, veterinary practices can create an environment where compliance is a shared responsibility. This not only minimizes the risk of diversion but also helps protect the practice from regulatory scrutiny and potential penalties. 

Controlled substance compliance is a shared responsibility that requires attention to detail, collaboration, and ongoing education. By addressing potential points of diversion, preparing for inspections, and prioritizing staff training, veterinary practices can safeguard themselves and their patients. It’s not just about having policies—it’s about following through every day.