Purpose

DivertGuard is a comprehensive diversion prevention program assessment tool designed for healthcare compliance professionals, pharmacy leaders, and controlled substance officers. It provides a structured, evidence-based framework to evaluate your program's maturity across critical control domains.

Domains Covered
Governance & Program Oversight
Controlled Substance Lifecycle
Perioperative & Procedural Controls
Data Analytics & Surveillance
Personnel & Access Controls
Physical Security
Incident Investigation
Regulatory Compliance
How to Use This Tool
  1. Select your institution type — Hospital, Community Pharmacy/Clinic, or Multi-Hospital System.
  2. Complete the checklist — For each item, check whether your program has that control in place. Items are weighted by importance.
  3. Review your score — Real-time scoring shows overall and per-section results. Identify gaps below 70% for priority action.
  4. Export and document — Use the CSV export to share results with your diversion committee or include in your annual program review.
  5. Repeat periodically — Run the assessment quarterly or annually to track program maturity improvement over time.
Methodology & Sources

The checklist items and weighting are derived from:

  • DEA regulations (21 CFR §1300-1316) and DEA Pharmacist's Manual
  • Joint Commission Medication Management (MM) Standards
  • ASHP Guidelines on Preventing Diversion of Controlled Substances
  • ECRI Institute patient safety guidance on drug diversion
  • State board of pharmacy regulations (various)
  • Published healthcare diversion prevention literature and industry best practices
Disclaimer

This tool is a self-assessment resource, not a substitute for professional legal or compliance advice. It does not guarantee DEA, Joint Commission, or state regulatory compliance. Always consult qualified legal and compliance professionals for your specific circumstances.

Current Features
  • Hospital, Community & Multi-Hospital assessment
  • Real-time weighted scoring with auto-save
  • CSV & PDF export of assessment results
  • Per-site checklists for multi-hospital systems
  • Investigation Playbook (6-phase workflow)
  • Policy Templates with working checklists
  • Training Materials & Red Flag Recognition
  • Regulatory Guide with DEA/state/JC references
  • Unit-Level Risk Assessment (6 care areas)
  • Interview & DEA 106 Filing Guides
  • Analytics Dashboard Blueprint with SQL
  • Camera Setup Guide with audit checklist
  • Communication Tips by audience
  • Useful Items — 12 downloadable PDF templates
  • Resource directory with 15+ regulatory links
About the Author

Alex Rodriguez, MHIIM, CPhT, is a drug diversion prevention program manager with more than 10 years of pharmacy experience spanning retail, hospice, compounding, home-health, and hospital settings. He has collaborated with hospitals, health systems, community pharmacies, and academic medical centers to design and strengthen controlled substance diversion surveillance programs. DivertGuard grew out of that hands-on work and the gaps he found in freely available guidance.

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