Monitoring, Reporting, and the Future of AI in Drug Diversion Prevention Programs

Deepika Nayyar, PharmD, MBA, BCPS, network pharmacy manager for quality, regulatory compliance, and accreditation at Hackensack Meridian Health (HMH), explains why diversion surveillance software alone is not sufficient. She describes the multidisciplinary auditing practices, procurement checks, and dispensing reconciliation processes HMH uses to catch what technology and artificial intelligence (AI) may miss. Additionally, there are federal and state reporting requirements for suspected diversion, including Drug Enforcement Administration (DEA) timelines. AI has the ability to help institutions move from retrospective, transaction-level review toward more proactive, risk-based detection; however, Nayyar emphasizes that clinical judgment and a supportive, human-centered approach must remain essential to any prevention program.

Pharmacy Times: What is your institution’s approach to ongoing monitoring and auditing? How often do audits occur, and what typically triggers a deeper review?

Deepika Nayyar, PharmD, MBA, BCPS: I wanna say we do use drug diversion surveillance programs, but none of these programs are perfect. There are pros and cons to every program or every software you use, so we have a multifaceted approach.

The program gives us the information on any unreconciled drugs, or it may give specific trends, but unless you look at the picture as a whole, you may not get the idea because it's gonna flag the data that is being fed. But not every single data point is going to be in the software. Examples could be if, a user is truly diverting drugs, they may document pain scores higher on a specific patient when pre- and post- this user, the pain scores were lower. And [if] the surveillance program is not analyzing that, we may not know, or if you don't interview the patient, you may never know. So that's why having that multidisciplinary approach, having [the] patient as a part of the team is really important.

And as far as frequency of auditing, it's really going to depend on what the institution needs. At HMH, we conduct regular auditing of every single process that we have, and then routinely look at any specific trends that rise to a level where we need to do a deeper dive.

The other thing I was going to say that's more on the administration dispensing part…also looking at the procurement part, there are so many things that we have in place currently. On the procurement side, the person who is ordering the drug is not the person who is signing off on the order, so we have 2 people looking at the order before it is signed. And then, the person who is receiving the order is not the person who is stocking it in the pharmacy controlled substance vault, or [they are] not the same person that ordered the drug. So having multiple people just ensuring that what you ordered is what was put in the stock, and then also looking at, monthly, weekly, daily reports [to ensure] that our math matches up.

So that's on the procurement side, and then I already discussed the administration dispensing side, [but] that math has to add up, and we continue regular monitoring.

Pharmacy Times: What are the key reporting requirements institutions need to be aware of, whether internally or to regulatory bodies like the DEA or state boards of pharmacy?

Nayyar: So the reporting requirements are gonna vary from state to state. Federally, DEA requires us to report any significant loss, drug theft, suspicious drug activity within 45 days, but the local DEAs must be informed within 1 day. The states may require Department of Health reporting, board of pharmacy reporting, licensing, reporting, law enforcement reporting, depending on the state, the laws are gonna be different.

Pharmacy Times: Where do you see drug diversion prevention heading in the next few years, particularly as technology and AI-driven surveillance continue to evolve?

Nayyar: I think we are in a very exciting phase. I love to talk about this topic. Like I said before, a lot of these programs have pros and cons, some are more developed than others. AI could really help us fill in that gap, rather than [having] manual audits look at and trying to identify trends or trying to see if this is a trend is established, if this is a meaningful trend or not. I think AI can help us with these things, and rather than having that retrospective approach—where most of the softwares are retrospective—having a proactive approach where it can identify those subtle patterns, which manually we would never be able to.

Another thing would be not to focus on individual transactions, focus on a picture as a whole. Have giving institution a specific score based on, you know, the risk. I think there are so many things AI could be beneficial in, but I think it's just how developed the AI is and [whether] we trust the AI data.

Pharmacy Times: Any final or closing thoughts?

Nayyar: One thing I forgot to mention, any software [or AI] we use, it doesn't replace clinical judgment, it enhances the process. The clinical judgment…when we're talking about diversion, everyone is human, so we need to put that human factor in there.

Another thing to consider is having policies and processes in place. If somebody has addiction issues or is having problems, they know the resources that the organization provides, so it never gets to the diversion. I think that's really important.

A couple [other] things I wanna highlight is having, you know, network governance or organizational governance, multidisciplinary approach, and multilayered or multifaceted tools to detect and prevent diversion. Last thing I want to mention is having a proactive rather than a reactive approach in these prevention programs.