What the public record shows

Counted from the DivertGuard case registry, which is compiled from board actions, court filings and press releases. It is a record of documented cases, not an estimate of how often diversion happens.

The guides, in order

14 guides on this topic.

Before the inspection

What investigators look at, and how long the process can run once it starts.

Inventory and recordkeeping

The inventory, the records behind it and how long each one has to be kept.

Ordering Schedule II drugs

Paper Form 222 and its electronic replacement.

Loss, theft, returns and destruction

Reporting a theft or significant loss, and documenting drugs that leave inventory for return or destruction.

Registration renewals

Keeping registrations current, and keeping routine counts going while a renewal is in progress.

What the assessment checks

The hospital assessment has 8 sections. These are the 8 items it scores under Regulatory Compliance:

  • DEA registration current and accurate for all sites
  • State controlled substance registration current (where applicable)
  • DEA biennial inventory completed on schedule
  • Controlled Substance Ordering System (CSOS) certificates current
  • Red flags from DEA Self-Assessment checklist addressed
  • Joint Commission controlled substance standards reviewed and current
  • State-specific controlled substance reporting requirements met (e.g., PMP)
  • Reverse distributor agreements current and destruction logs complete

The other sections: Governance & Program Oversight (7), Controlled Substance Lifecycle Management (9), Perioperative & Procedural Areas (6), Data Analytics & Surveillance (9), Personnel & Access Controls (8), Physical Security (7), Incident Reporting & Investigation (9). Each item is weighted, the score updates as you answer, and the result exports to PDF or CSV.

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Last reviewed: September 2026 · Content is educational, not legal advice.