Category: Facility oversight

  • Drug diversion in long-term care

    Why controlled-substance diversion is escalated late, what it costs residents, and why an anonymous route to ownership is the only one that gets used.

    Of everything that goes wrong in a facility, diversion is the problem most likely to be handled locally for as long as it possibly can be — and the one where that delay costs the most.

    Two victims, one of whom is invisible

    The obvious harm is to the facility: a controlled-substances problem, a documentation problem, an employment problem. The less obvious harm is the resident whose pain medication is not reaching them, whose pain is therefore unexplained, and whose distress may then be read as a behavioral issue and treated as one.

    That is the loop worth naming. Diversion can present as agitation in a resident nobody thinks to connect to the medication cart.

    Why it is escalated late

    A count discrepancy implicates a named person the manager works beside every day. The sequence is human: look again, watch, move a schedule, wait for certainty. Every step is time, and the documentation trail during that time is being built by the person with the most reason to shape it.

    Who actually notices first

    A colleague. Almost always. And a colleague will not put their name on an accusation about a coworker inside a building they have to keep working in — which is why an anonymous route out of the building is not a nicety here. It is the only route that gets used. Who can report.

    What the safety review checks

    • Medications stored in locked, secure cabinets.
    • Expired medications disposed of properly.
    • Accurate medication administration records.
    • Compliance with pharmacy storage guidelines, including temperature control.
    • Medication logs updated daily for residents with cognitive impairments.
    • Immediate reporting of medication errors and adverse events.
    • Staff trained to identify adverse reactions in memory care residents.

    For ownership

    This is the category where the distance between “we caught it in week one” and “we found out during an investigation” is widest. What specific consequences attach to a given facility depends on the facts and its registrations, and that is a question for its counsel rather than for a website. Drug diversion and federal exposure.


    What the evidence shows about diversion

    It harms patients, not only budgets

    A CDC review covering 2000 to 2013 identified six outbreaks of infection caused by drug diversion by US health care personnel. Two involved tampering with opioids given through patient-controlled analgesia pumps and produced gram-negative bacteremia in 34 patients; four involved tampering with fentanyl syringes or vials and transmitted hepatitis C to 84 patients. Nearly 30,000 patients were potentially exposed to blood-borne pathogens and had to be notified and offered testing.

    A single later investigation, traced to one travelling technician diverting fentanyl, identified 32 of 1,074 catheterization-laboratory patients infected with the outbreak hepatitis C strain — described as the largest laboratory-confirmed diversion-associated hepatitis C outbreak published to that date.

    Those outbreaks occurred in hospitals rather than in long-term care. They are cited here because they establish the mechanism and the scale of the notification problem, not because an equivalent long-term care series exists.

    How common it is in settings adjacent to long-term care

    A national stratified random survey of US hospices (371 of 600 responded) found that 43% of hospice representatives reported missing opioid medications within the previous 90 days. Fifty-two percent reported that employees were not allowed to dispose of medications after a home death, and among home deaths unused opioids were left in the home 32% of the time.

    Why it is a system problem rather than a bad-apple problem

    A scoping review of 312 articles concluded that there are “a large number of contributors to drug diversion in all stages of the medication-use process” and that “all health professions and clinical units are at risk.” That framing matters for an owner, because the alternative framing — that diversion is a hiring failure — produces a response that does not work.

    Detection lag is the variable you can change

    A study developing and validating an analytics model across 10 hospitals in four health systems, covering 27.9 million transactions and 22 known blinded diversion cases, found the analytics detected those cases a mean of 160 days and a median of 74 days faster than existing detection methods (range 7 to 579 days faster).

    That is the whole argument for an anonymous channel that goes past local management: the constraint is almost never whether anyone knows, it is how long it takes for what someone knows to reach a person who can act.

    References

    1. Schaefer MK, Perz JF 2014. Outbreaks of infections associated with drug diversion by US health care personnel. Mayo Clinic Proceedings 89(7):878-87. [CDC record and literature review, 2000-2013] · PMID 24933292 · doi:10.1016/j.mayocp.2014.04.007
    2. Alroy-Preis S, et al. 2018. Large outbreak of hepatitis C virus associated with drug diversion by a healthcare technician. Clinical Infectious Diseases 67(6):845-853. [outbreak investigation with viral sequencing] · PMID 29767683 · doi:10.1093/cid/ciy193
    3. Cagle JG, et al. 2021. A national survey of challenges faced by hospices during the opioid crisis: estimates of pain medication shortages, missing medications, and opioids left in the home post-death. Journal of Pain and Symptom Management 62(4):738-746. [national stratified random survey, 371 hospices] · PMID 33652093 · doi:10.1016/j.jpainsymman.2021.02.023
    4. Fan M, et al. 2019. Diversion of controlled drugs in hospitals: a scoping review of contributors and safeguards. Journal of Hospital Medicine 14(7):419-428. [scoping review, 312 articles] · PMID 31251158 · doi:10.12788/jhm.3228
    5. Knight T, et al. 2022. Detecting drug diversion in health-system data using machine learning and advanced analytics. American Journal of Health-System Pharmacy 79(16):1345-1354. [multi-site model development and validation] · PMID 35136913 · doi:10.1093/ajhp/zxac035
  • Wandering and elopement: what the review checks

    Twelve of the 189 checklist items cover wandering prevention and cognitive-impairment safety. What they are, and why signage counts as a safety measure.

    Elopement is the failure mode a memory-care unit is judged on, and most of the prevention is unglamorous: doors, alarms, signage, and knowing which residents are at risk.

    Wandering prevention and security — six items

    • Secured entrances and exits, for example locked doors with keypads.
    • Alarm systems or monitoring devices at all exits.
    • Staff awareness of residents at high risk for wandering.
    • Enclosed outdoor areas that are safe for resident use.
    • Emergency exit doors equipped with alarms or security systems.
    • Clear signage and visual cues to help residents navigate the facility.

    Resident safety for cognitive impairments — six items

    • Elopement prevention plans in place for at-risk residents.
    • Rooms free of sharp objects or items that could cause harm.
    • Monitoring systems, such as cameras or staff checks, for high-risk residents.
    • Non-toxic, safe cleaning supplies in resident areas.
    • Secure storage of medications, cleaning supplies and hazardous materials.
    • Easily accessible emergency call systems in resident rooms.

    Why signage is on a safety list

    Because a resident who cannot find their own room is a resident who will keep walking, and a resident who keeps walking is the one who finds the door. Large legible signs, visible clocks and calendars, and calm decor without disorienting patterns are prevention, not decoration. They sit in the Environmental Comfort & Design category alongside temperature and noise control, and they reduce the agitation that produces the exit-seeking in the first place.

    The two failures that show up together

    An elopement plan that exists on paper and a staff group that cannot name the at-risk residents is the commonest pairing. The second item on the list — staff awareness — is the one that makes the other five work.


    All 40 memory care items · Well-being and cognitive enhancement.


    What the evidence says

    Wandering is one of the core behavioral and psychological symptoms of dementia, and “one or more of these symptoms will affect nearly all people with dementia over the course of their illness.”

    A scoping review that screened 3,376 articles and included 73 identified 27 variables associated with missing incidents among people living with dementia, grouped into demographics and personal characteristics, health conditions and symptoms, and environmental and contextual antecedents. Its statement of the stakes is short: “The adverse outcomes of going missing include injuries, death, and premature institutionalization.”

    The variable that matters most is time

    A nationwide Swedish registry study of 1,041 police missing-person reports concerning people living with dementia found the person was harmed in 61 cases (6%), with harm ranging from lacerations to death. Male sex, no prior missing incident, cold season, time since last contact, delayed reporting and prolonged search duration were all associated with increased probability of harm — and “time was a critical factor, emerging as the strongest predictor of harm in the study.”

    That is the case for an escalation protocol with a clock on it rather than a search that starts informally. It is also why the review checks staff awareness of which residents are at risk separately from whether alarms exist: the first minute is spent knowing who is missing.

    Wandering and falls are the same population

    An analysis of 282,518 assessments covering 75,132 long-term care residents found that unstable health, unsteady gait, wandering and moderate to severe dependency in activities of daily living were the strongest risk factors for falls, and that cognitive impairment carried a hazard ratio between 1.22 and 1.37 across the periods studied.

    References

    1. Kales HC, Gitlin LN, Lyketsos CG 2015. Assessment and management of behavioral and psychological symptoms of dementia. BMJ 350:h369. [clinical review] · PMID 25731881 · doi:10.1136/bmj.h369
    2. Perez H, Miguel Cruz A, Neubauer N, et al. 2024. Risk factors associated with missing incidents among persons living with dementia: a scoping review. Canadian Journal on Aging. [scoping review, 73 studies] · PMID 38297497 · doi:10.1017/S0714980823000776
    3. Larsson M, Årestedt K, Svensson A, Andersson H, Wolmesjö M 2025. Missing incidents and the risk of harm in persons living with dementia reported to the Swedish police: a nationwide retrospective registry study. BMC Geriatrics 25(1):153. [nationwide registry study, 1,041 reports] · PMID 40045223 · doi:10.1186/s12877-025-05809-9
    4. Cheung G, et al. 2024. Falls risk in long-term care residents with cognitive impairment: effects of COVID-19 pandemic. Journal of the American Medical Directors Association 25(1):177-182. [observational, 75,132 residents] · PMID 38104633 · doi:10.1016/j.jamda.2023.11.006
  • The gap between the floor and the owner

    Why information about problems travels worst through the chain that is supposed to carry it, and what an off-site owner can actually do about it.

    Every report that reaches an owner has passed through the people the report is about. That is not a moral claim. It is a description of the reporting line.

    The filter is made of reasonable decisions

    A site manager who receives a complaint about staffing is receiving a complaint about their own staffing. The sequence that follows is familiar and defensible at every step: I will fix this before I raise it. This one is not representative. Corporate will overreact, and then I will lose the flexibility I need. Each of those is a judgment a competent manager is paid to make.

    The aggregate is an owner who learns about a six-month pattern from an attorney’s letter.

    What travels badly, specifically

    • Patterns rather than events. One short shift is noise. Nine short shifts on one hall is a finding — and only someone counting across weeks can see it.
    • Repeat complaints that were closed. The fourth report of the same broken call light is the important one and the least likely to be escalated, because the first three were resolved.
    • Anything implicating the reporter. Which is most of what an owner needs.
    • Controlled-substance discrepancies. These are handled locally for as long as they possibly can be. Drug diversion and federal exposure.

    Why “escalate more” does not work

    Owners ask for it constantly and it changes nothing, because the request does not change the incentive that produced the filtering. The manager is still judged on the absence of visible problems. Asking someone to volunteer evidence against their own metric is asking for a favor, not building a system.

    What does work

    A route the incentive does not sit on. A QR code in the building, usable by employees, families, visitors and contractors, without a name, transmitting to ownership and to the attorneys ownership designated. Local management is not on the route, which is the entire mechanism. The reporting channel.

    A fixed external list. The same 189 items in the same 54 categories every visit, so a finding in March and the same finding in September read as a pattern rather than as two opinions. The safety review.

    The part owners get wrong

    Introducing the channel as a check on management turns it into a loyalty test and it dies within a quarter. Introduced properly, it is a route for people who would otherwise say nothing, and most of what comes through it is maintenance and process rather than misconduct. Tell your managers before the codes go up. Ownership and management.