Health system pharmacy leaders face the dual challenge of navigating a rapidly evolving drug supply chain while maintaining day-to-day compliance with controlled substance regulations across hospitals and clinics. Whether managing a single-site operation or directing a large academic health center, pharmacy teams consistently encounter issues related to medication procurement and internal oversight—processes that are critical to patient and community safety.
To address these challenges effectively, health systems must cultivate a culture rooted in awareness, transparency, and safety in medication use and drug diversion prevention. Although pharmacy typically plays a central role in diversion prevention, successful programs require collaboration across departments—including nursing, compliance, risk management, security, and executive leadership.
Navigating Regulatory Pressures
Over the past 5 years, an increase in Drug Enforcement Administration (DEA) inspections and enforcement actions has prompted health systems to develop more innovative approaches to diversion monitoring.1 At the same time, these organizations must respond to increasingly complex diversion tactics. According to the State of Drug Diversion 2025 Report, 25% of respondents identified compliance with federal and state regulatory requirements as a top priority for their executive boards regarding diversion prevention.2
Health systems are expected to implement robust policies and procedures that prepare them for unannounced DEA visits or follow-up from reported incidents.3 These inspections may involve evaluating physical spaces and equipment, such as automated dispensing cabinets, auditing controlled substance inventories, and reviewing required documentation for accuracy. Noncompliance can result in severe financial penalties, legal consequences, and disruptions to patient care.4 To protect staff and patients, diversion surveillance must be supported by a multidisciplinary team, strong leadership commitment, advanced technology, and regular assessments of regulatory readiness.
The American Society of Health-System Pharmacists emphasizes pharmacy’s leading role in medication management and controlled substance diversion oversight.5 Many organizations follow these guidelines, with the State of Drug Diversion 2025 Report confirming that pharmacy is recognized as a key stakeholder in most programs.2
Still, achieving broad multidisciplinary participation remains a challenge. For example, only one-third of respondents reported including anesthesiology—despite its high-risk nature—and just one-fifth involved human resources. Incorporating diverse professional perspectives enhances risk assessment and pattern detection while encouraging a culture of shared responsibility and vigilance.
The Case for a Multidisciplinary Approach
Each hospital system has distinct workflows to consider when forming a drug diversion committee. As regulations evolve, continuous evaluation of preparedness is essential. A multidisciplinary approach promotes shared accountability, timely communication, and proactive prevention. Assembling a core team that understands the unique operations of each department can improve the program’s efficiency.
Effective surveillance requires input from clinicians familiar with the nuances of different care settings. For instance, perioperative and procedural areas often have workflows distinct from general medical units. Involving perioperative specialists can be crucial in shaping appropriate policies and tailoring software solutions to meet specific needs.
Emergency departments bring their own challenges. The use of emergency kits and the need to act quickly—often with incomplete patient data—requires careful oversight. Paramedics and allied health professionals frequently assist with medication administration in these settings, demanding additional scrutiny. A nursing leader who understands these dynamics can improve protocols and support diversion-resistant workflows.
Pharmacy purchasing and distribution also vary depending on patient demographics and care delivery models. Ordering and receipt processes may be known only to a select few, making the insight of a pharmacy manager or operations director invaluable.
Centralized diversion detection programs have proven effective when they involve a range of professionals across the organization. For example, HCA Midwest in Kansas City, Missouri, highlights the value of pharmacy-nursing collaboration in preventing incidents before they occur.⁶
An ideal diversion committee should include representatives from pharmacy, nursing, compliance, informatics, security, and a physician champion. Where resources allow, consider expanding to include risk management, law enforcement, human resources, infection prevention, employee health, and diversion analysts.
To support program success, consider these practical steps:
