Overview

All opioid treatment programs (OTPs) should have diversion control practices in place to prevent or reduce the possibility of methadone or LAAM being diverted from the program by either staff members or clients. This plan is a requirement from the Center for Substance Abuse Treatment (CSAT) guidelines and the new Federal regulations in CSAT Guidelines for the Accreditation of Opioid Treatment Programs, 66 FR 4076; January 17, 2001.

Accreditation Requirement(s)

To be in conformance with this accreditation standard, the organization must show evidence of the following:

• The Diversion Control Plan demonstrates to clients and the community that the organization is accountable to them and is providing quality care.
  
• The plan includes clinical and administrative monitoring.
  
• Problem identification, correction, and prevention should be part of the plan.

Implementation Tips

Some Implementation Tips provided, in part, by Robert Johnson at: www.accreditationnow.com.

• First, assess the steps that are currently being taken to prevent the diversion of methadone or LAAM from the OTP.
  
  
• The Diversion Control Plan can be part of the organization's quality and performance improvement program. The plan should contain specific measures to reduce the possibility of diversion of controlled substances from legitimate treatment use, and should assign specific responsibility to the medical and administrative staff for implementation.
  
  
• The goal is to reduce the scope and significance of diversion and its impact on communities.
  
  
• The Diversion Control Plan should contain a mechanism for periodic monitoring of clinical and administrative activities to reduce the risk of medication diversion. A mechanism for problem identification and correction and for prevention of related diversion problems is the hallmark of a good plan.
  
  
• A part of the Diversion Control Plan should be surveillance and monitoring of potential diversion and community problems, which may be associated with opioid agonist treatment. One of the goals of surveillance and monitoring is to answer the questions, “Is there a diversion problem? And if so, how does the clinic or the community know?” For example, some clinics may set up a system of rounds in which security or clinic staff walks around the perimeter of the clinic on a regular and periodic basis to assess the activities at the entrances, in hallways, alleys, and the parking lot. This simple system of regularly checking the environment will help the program assess whether it has a loitering or diversion problem close to the clinic site.
  
  
• The clinic should examine its dosing and take-home dispensing practices to ensure that there are no potential weaknesses in the dispensing of medication that could lead to diversion problems.
  
  
• Another example of surveillance and monitoring involves consulting periodically with law enforcement in the community and in areas where patients live to discuss surveillance findings and the perceived and actual problems encountered.
  
  
• It may be helpful to assign diversion problem identification, correction, and prevention functions to one of the clinic's committees, such as the quality and performance improvement committee or the management committee. If the clinic is small, there may be only one committee for all staff and management business.
  
  
• If a diversion problem is identified, how should it be addressed? Several strategies may be helpful. Always investigate the alleged or actual source of diversion. If needed, change the frequency of take-home reviews. Drug testing regimes may have to be reevaluated. Special, intensified groups or individual counseling sessions may be helpful for individuals or groups at risk for diversion problems. Patient committees to advise on policies, procedures, and problem solving may also help by giving patients a voice in keeping the treatment environment therapeutic and safe.
  
  
• Your Diversion Control Plan can also address the CARF standard for preventing multiple enrollments (4.B.13) instead of having a separate written procedure on efforts to prevent clients from being enrolled in more than one OTP.