Controlled drugs discrepancies

What do I do if I identify a discrepancy in my controlled drugs reconciliation?

Controlled drugs discrepancies can happen for a number of reasons and, when they happen, it is important to increase the focus on controlled drug custodianship and reconciliation.

Consider the seriousness of the discrepancy and decide whether the issue should be escalated. Seriousness can depend on both the nature and the volume of the drug involved. For example, both a situation involving a low volume of a high risk controlled drug and a high volume of a lower risk controlled drug could be sufficiently serious to escalate. More serious cases should be escalated because they could raise a number of issues, including workplace health and safety, potential criminal offending and potential breach of the Code of Professional Conduct. If you are in doubt as to whether to report, contact us to discuss.

The responsibility for the controlled drugs and any discrepancies remains with the veterinarian even after reporting to VCNZ (or other authorities, such as the Police).

The veterinarian should work through possible explanations for the variances and undertake a systematic review by performing the following steps:

1. Perform a follow up reconciliation using a second team member and include assessing:
   1. Drug ordering and receipting into stock
   2. Drug usage and recording (e.g. missed charges etc)
   3. Variances and their recording due to:
      1. syringe/hub residues
      2. waste of unused drug
      3. expired drug
      4. drug drawn up versus invoiced/recorded drug volumes.
2. Review access to the controlled drug safe.
3. Consider potential health and safety risks if the drug is diverted for personal use and the potential for self-harm:
   1. Are there any vulnerable people that may have accessed the drugs?
   2. What steps can you take to protect their welfare?

For non-serious discrepancies (e.g. small quantities of lower risk drugs), the veterinarian may decide to draw a line as of the current stock take and simply start with the new and correct drug balances from that date forward. It would be prudent to ensure that all reconciliation from this point is accurate, regularly audited and accounted for.

Possible remedies if the discrepancy is potentially serious:

1. Appoint an external investigator (vet) to review all weekly controlled drug audits, and consider whether this is a simple irregularity or a more serious incident. They may go into the clinic in person to visually check all hard copies of invoices receipted in, and also review our controlled drug book for any unusual entries.
2. Arrange for a two-code safe system to be installed to prevent one person taking drugs out of the safe alone.
3. Consider the psychological health and safety of all staff with access and address any issues immediately.
4. Perform a systems audit, checking the incoming and outgoing stock processes. This could include reviewing supplier invoices to check that controlled drugs coming in, are being receipted in to the clinic, and added into systems stock (stock reconciliation); and reviewing recording and invoicing systems to check appropriate usage records.
5. Review roster and attendance data to check if any patterns are apparent in staffing when there have been controlled drug variances reported.
6. Consider engaging with a health and safety specialist to ask for advice on how to keep our teams safe, and also initiate a further investigation.
7. Considering the risk decide whether to remove controlled drugs from the clinic.
8. Consider an external health and safety investigator to perform on site interviews using a root-cause or Incident Cause Analysis Method (ICAM) investigation process.
9. Review current policy and practices in clinic to identify any further opportunities and risks, and address these.
10. Consider reporting the missing stock to the police as this may trigger a criminal investigation.

Any concerns regarding the conduct of a veterinarian in relation to controlled drugs discrepancies would be best reported to VCNZ. We are mindful that these issues are often linked to the health of the person involved and will take a sensitive and rehabilitative approach to the issue, where possible. If you have concerns or questions, you are welcome to call us of a confidential (and optionally anonymous) discussion.