ONBOARDING
New Hire Diversion Awareness Training

Required for all new employees with any access to controlled substances. Delivered within the first 30 days of hire. Duration: 30-45 minutes.

Training Outline
1. The Scope of the Problem
  • How healthcare workers divert — national statistics
  • Impact on patients (pain mismanagement, infection risk)
  • Impact on the diverter (license, career, criminal liability)
  • Impact on the organization (regulatory fines, reputation)
2. Your Role in Prevention
  • Proper medication handling — every time, no shortcuts
  • Waste documentation requirements
  • Securing medications at all times
  • Never share login credentials or badges
3. Reporting Concerns
  • How to report — anonymous reporting mechanism
  • What to report — discrepancies, behavioral concerns, policy violations
  • Non-punitive culture — reporting is not retaliation
  • What happens after a report (investigation process overview)
ANNUAL
Annual Competency Training

Required annually for all CS-touching staff. Builds on new hire content with deeper case studies and organizational-specific data. Duration: 45-60 minutes.

Required Content
  • Organizational diversion metrics over the past year — total discrepancies, investigations, outcomes
  • Lessons learned from any confirmed diversion events in the organization or region
  • Policy updates since last training
  • Case study — real diversion scenario with discussion questions
  • Waste witnessing demonstration and return-demonstration
  • Behavioral observation — signs of impairment (video or role play)
Common Training Gaps
  • Annual training that is identical to new hire training — staff tune out. Use case studies, not slides.
  • No unit-specific content — ED diversion differs from OR diversion. Tailor examples.
  • No knowledge check — reading slides is not training. Use scenarios and test comprehension.
  • Training completion tracked but not effectiveness — measure whether staff can identify red flags after training.
RECOGNITION
Red Flag Recognition — By Category
Category Red Flags What to Do
Behavioral Volunteers to administer CS for colleagues; frequent bathroom breaks after handling CS; unwilling to take breaks; arrives early / stays late frequently; defensive when CS policies are discussed Document specific observations with dates/times. Report via confidential mechanism. Do NOT confront.
Transactional High override rate; high waste rate; frequent admin-access transactions; removing CS under wrong patient; multiple removals from same cabinet in short window Review ADC reports. Compare to unit/peer averages. Flag if > 2 SD from mean. Cross-reference with camera footage.
Documentation Waste documented without witness; administration charted when patient reports no effect; pain scores don't change after CS administration; documentation timestamps outside normal workflow Audit MAR against pump logs. Review waste documentation for missing witness fields. Check for timing anomalies.
Physical Track marks on arms/legs (long sleeves worn in warm environments); pinpoint pupils or dilated pupils; runny nose/nosebleeds; tremors; excessive yawning; drowsiness during shift; odor of alcohol Document observations. Report to supervisor immediately. Do NOT accuse. Initiate fit-for-duty evaluation.
Inventory Controlled substance counts consistently off; narcotic waste not matching dispense records; expired CS not returned on schedule; ADC restocking discrepancies Escalate to pharmacy management. Conduct focused perpetual inventory review. Review ADC transaction logs for pattern.
PROCEDURE
Waste Documentation Training

The most diverted medications in healthcare are never reported missing — they're documented as waste. Proper waste witnessing is the single most effective behavioral control.

Proper Waste Witness Procedure
1
Prepare

Witness confirms the medication name, dose, and route. Verify against MAR.

2
Observe

Watch the entire destruction — medication placed in waste receptacle, residual volume visible.

3
Document

Witness documents the waste event in the ADC/EHR with their credentials. Includes time, drug, volume, and method of destruction.

4
Reconcile

Waste volume reconciled against dispense volume at shift change and ADC restocking.

NEVER pre-sign waste documentation. NEVER witness waste you didn't physically observe. NEVER document waste for a colleague who is not present. Falsified waste documentation is grounds for termination and may result in criminal charges.

SAFETY
Impairment Recognition — Signs of Substance Use in Healthcare Workers
Behavioral Changes
  • Mood swings — irritability, euphoria, depression
  • Isolation — avoiding colleagues, eating alone, hiding
  • Defensiveness when questioned about medication handling
  • Frequent absences, especially after days off
  • Declining performance or increased errors
  • Volunteering for extra CS-related tasks
Physical Signs
  • Pinpoint or dilated pupils
  • Runny nose, frequent nosebleeds (insufflation)
  • Track marks — long sleeves in warm environments
  • Tremors, unsteady gait, poor coordination
  • Excessive yawning, drowsiness during shift
  • Weight loss or flushed skin
Practice Changes
  • Waste documentation errors or missed witness signatures
  • Overrides significantly above peer average
  • Requests to cover high-opioid patient assignments
  • Patients reporting inadequate pain relief despite charted medication
  • Signing out CS under wrong patient then correcting later
  • Frequent ADC transactions outside normal workflow
REPORTING
Incident Reporting — How It Works
What to Report

You don't need proof. You just need a concern.

  • You see a colleague waste CS without a witness
  • A patient reports they didn't receive pain medication that was charted as given
  • You notice a colleague behaving differently after handling CS
  • Controlled substance count is off and you can't find the discrepancy
  • A colleague asks to borrow your login or badge
  • You find a syringe or vial in an unexpected location
How to Report

Multiple reporting channels — use whichever you're comfortable with.

  • Anonymous hotline/portal — no name required, available 24/7
  • Direct to supervisor — in-person or email
  • Pharmacy leadership — call or email the diversion officer directly
  • Incident reporting system — file a medication event report

Non-punitive culture: This organization has a zero-tolerance policy for retaliation against anyone who reports a concern in good faith. If you experience or witness retaliation, report it immediately.