Controlled Substance Diversion (9%) |
Consequences of diversion (e.g., infection risks to patients, organizational liability, fines/indictments, fraud charges, loss of job and/or license) |
Signs of impaired health-care workers (e.g., mood changes, agitation, dilated pupils, sudden declines in job performance) |
Motivations to divert CS (e.g., addiction, financial gain, recreation) |
Controlled Substance Diversion Prevention Program (30%) |
Areas of vulnerability in procurement, preparation and dispensing, prescribing, administration, and waste/removal processes |
Elements of a comprehensive and effective controlled substances diversion prevention program (CSDPP) |
Types and functions of security control measures, devices, and software to detect and prevent diversion (e.g., locking storage, cameras, ADCs, analytics software) |
High risk areas of the pharmacy (e.g., anesthesia area, CS vault, IV room, will call, receiving) |
Chain of custody methods (e.g., regulation of access control, presence of witnesses for signing delivery sheets, use of tamper-evident containers) |
DEA Requirements (38%) |
DEA registration requirements (e.g. power of attorney, renewal) |
Procedures to validate DEA numbers (e.g., formula and component parts of the DEA number) |
Contents, appropriate usage, and record keeping for DEA form 222 |
DEA Controlled Substance Ordering System (CSOS) |
Contents, appropriate usage, and record keeping for DEA form 41 |
Contents, appropriate usage, and record keeping for DEA form 106 |
Knowledge of DEA scheduled medications and which are at high risk for diversion |
DEA requirements for conducting physical inventories and record keeping |
Contents, appropriate usage, and record keeping for DEA form 107 |
Actions to take during a robbery or theft event |
Procedures for sales of CS and restricted OTCs (e.g., pseudoephedrine) |
Surveillance and investigation (23%) |
Suspicious data patterns (e.g., waste buddy, night shift sedation, cancel removes, pocket inventory, anomalous usage) |
Surveillance practices and techniques (e.g., reconciliation of invoices to purchase history reports, check list to verify all paperwork is complete, records audits) |
Signs of product tampering and/or alteration (e.g., vials tops that don’t twist easily, chipped tablets, drug assay sampling) |
Signs of and methods to detect fraudulent prescriptions |