Operational Red Flags

Even in the absence of behavioral concerns, your system itself may reveal signs of diversion. DEA inspections often focus on logbook accuracy, inventory reconciliation, and waste documentation.

Red Flags to Watch For:

🔸 Inventory Discrepancies

• Physical counts don’t match logbook entries
• Items go “missing” with vague explanations
• More frequent ordering than clinical volume requires

🔸 Incomplete or Altered Logs

• Log entries with missing initials or times
• Erasures, white-out, or inconsistent handwriting
• Backdated or out-of-sequence entries

🔸 Suspicious Breakage or Waste Reports

• Regularly reported “dropped vials”
• High volumes of wasted or expired drugs
• Lack of dual-signatures for waste documentation

🔸 Refill Patterns and Ordering

• Frequent reordering of Schedule II or III drugs
• Orders placed just before weekends or holidays
• Discrepancies between invoice quantities and logged inventory

🔸 Forged or Copied Signatures

• Signatures that look identical across different dates
• Use of non-permanent ink (like pencil or erasable pens)
• Signatures on days the staff member was not working

Reference the DEA’s Own Checklist:

The DEA uses a variety of criteria to assess risk during inspections. Common operational failures cited include:

• Failure to maintain initial inventory
• Poor record-keeping on administration and disposal
• Lack of documented security protocols

💡 Pro tip: Every controlled drug entry should be:

• Complete (who, what, when, how much)
• Clear (legible and unambiguous)
• Consistent (matches with invoices, patient records, and logbooks)