Dirty little secrets
Don’t assume your practice is immune to employee drug diversion. Failure to conduct background checks and take other preventive steps can invite a visit from authorities.
All individuals at some point are confronted with the Eighth Commandment: Thou shall not steal. According to the FBI, employee theft, or “shrinkage,” is the fastest-growing crime in the United States and is more prominent than identity theft, cyber fraud, credit card theft and internet scams.
Research shows that 75 percent of employees have engaged in some form of theft. In many cases, warning signs like these are overlooked:
- Declining profits.
- Unexplained inventory shortages.
- Accounting discrepancies.
- Unusual employee behavior.
When theft is identified, many veterinary practices fail to deal with it until they are faced with a negative financial impact, or worse, serious criminal activity.
A Prime Target
Veterinarians, as dispensers and prescribers of controlled substances, are a prime target for drug addicts. Veterinarians have access to a large variety of controlled and noncontrolled substances. As America’s opioid epidemic and addiction rates continue to soar, employee drug theft is a rising occupational hazard.
The veterinary profession has become ripe for internal theft because of minimal internal management of controlled substances, an often-lax approach to routine drug testing and background checks of new employees, and manual inventory practices. The environment has become so toxic that some employees are willing to do whatever is needed to get their hands on controlled substances.
Take, for instance, these local news blurbs:
- A Florida veterinary technician was arrested on suspicion of stealing controlled substances from two of the veterinary clinics where she was employed.
- A Massachusetts veterinary technician was charged with stealing 7,800 opioid pills and trying to cover her tracks by changing clinic records.
- A woman was arrested on 20 counts of possession of controlled substances in connection with a theft from the Auburn University College of Veterinary Medicine.
- A Wyoming veterinary receptionist was accused of stealing tramadol and fraudulently calling in prescriptions.
These cases stand as a cautionary warning that no veterinary practice is exempt from internal theft. It can happen anywhere if preventive steps aren’t taken. While stopping theft completely might be impossible, measures can be instituted to mitigate and deter illegal activity.
Know Your Employees
A multitude of reasons exist for why a veterinary practice might lack measures to counteract internal theft. Some practice leaders trust their employees completely — “They wouldn’t steal from me.” For others, setting up proactive measures could be put off because of a lack of time or a belief that implementation costs would be too high.
In many practices, a family environment exists, so friends and relatives are hired without proper background checks and drug screenings.
At the end of the day, a bit of upfront time can save practice owners tons of time, money and heartache and at the same time protect staff members, clients and patients from costly, or even deadly, mistakes.
Here are the potential costs of failing to take steps to safeguard controlled substances:
- Federal and state civil fines.
- Attorney, remediation and investigation fees.
- Loss of inventory and suppliers.
- Government oversight monitoring plan.
- Drug Enforcement Administration registrant and rehabilitation program fees.
- Lost revenue from employee turnover.
Signs of Employee Theft
All criminals have a “tell,” or a pattern that unsuspecting victims can become aware of to better protect and keep themselves out of harm’s way. Employee theft is no exception.
The question should not be whether an employee will steal from your practice but rather what you can do to detect the early signs and stop a theft before it happens.
Here are red flags that a problem might exist:
- Pages are missing from the controlled substance manifest.
- Prescription pads are missing.
- An employee claims a drug bottle was “lost,” “destroyed” or “thrown away by mistake,” but you hear the explanation with suspicious frequency.
- A doctor or nurse insists that he always logs in certain pharmaceutical deliveries, but it’s not one of his usual responsibilities.
- Management refuses to upgrade or even initiate a controlled substance log.
- Associates or partners hold veterinary distributor accounts with delivery addresses other than the practice location.
The best defense against internal theft can start with answers to these questions:
- Have thorough background checks been conducted on all employees at your hospital? Were they administered a standard seven-panel drug urine test for marijuana, cocaine, opiates, PCP, amphetamines, benzodiazepines and barbiturates?
- Does your clinic have an up-to-date controlled substance policy and procedure manual for establishing and maintaining effective anti-diversion controls?
- Do you have video surveillance of controlled substance storage and inventory areas?
- Is the disposal of controlled substances witnessed by two authorized employees?
If you answered “no” or “I don’t know” to any of these questions, you could be at risk for internal theft, noncompliance or both.
Who Works for You?
Free time is a rare commodity in veterinary medicine. In addition to being overworked and overextended, many veterinary professionals repeatedly engage in an “all-hands-on-deck” environment. Problems occur when everyone is focused on bailing water out of the ship and not looking for other potential threats.
Preventing employee theft is far easier than trying to mitigate an ensuing problem. Veterinary practices looking to prevent and protect themselves from the threat of internal drug theft should consider incorporating the following four strategies:
- Screen all employees before hiring them — the best defense against internal theft. Not only is this step a matter of business necessity and essential to overall controlled substance security, it is a requirement that every DEA registrant conduct a background check on any employee who will be authorized to work with the controlled substance inventory. If you do not conduct a criminal background investigation and drug screening as part of your onboarding procedures, you are placing the practice and your livelihood at risk of criminal exposure and potential fines. I also recommend random drug screening of employees.
- Train your employees. Does your practice have a standard operating procedures manual? Does the manual spell out a policy of performing a background investigation and drug screening of each new employee?
- Advise employees that the consequence of theft can be termination. In addition, the theft of controlled substances is a federally indictable offense and the potential losses might include a license revocation, a financial loss and the damaged reputation of the individual and organization.
- Review your systems. How sure are you that the controlled substances kept at your hospital are secure and that your procedures meet the requirements of the DEA Controlled Substances Act? Ensure that your security measures, inventory controls and recordkeeping systems are up to date. This starts with a thorough assessment to ensure that vulnerabilities are identified and remediated.
Prepare for the Inevitable
Be prepared. Business is tough, and America’s opioid epidemic has made operating and sustaining a secure, viable veterinary business even harder.
Having an action plan that empowers you to respond quickly, along with a robust policy and procedures manual describing best practices, is key.
Knowing your employees is a never-ending process. Employee theft will never disappear, but with the right preventive measures in place, the problem does not have to be yours.
In the words of A.E. Housman, it’s best to prepare for the worst because “luck’s a chance, but trouble’s sure.”
Jack Teitelman is the founder and president of Titan Group, a regulatory compliance, drug security and anti-diversion solutions provider. He is a retired U.S. Drug Enforcement Administration supervisory special agent.