Responding to Suspected Diversion

Courtney on April, 2025

When diversion is suspected, clinics must act swiftly and with discretion.

Internal Investigation Steps

  1. Isolate the suspected breach — remove staff access as needed.
  2. Conduct a preliminary review of logs, surveillance, and records.
  3. Interview relevant staff in a neutral, confidential setting.
  4. Document all findings.

DEA Reporting

If a significant loss or theft is confirmed:

  • Notify the DEA Field Office within 1 business day.
  • File DEA Form 106 electronically at DEA Diversion Control website.
  • Retain a copy of the form for two years.

When to Involve Law Enforcement

Contact local police if:

  • Diversion involves criminal behavior
  • Drugs are found offsite
  • Patient or public safety is threatened

Always consult your attorney or practice insurer if unsure.