Staff Training & Internal Protocols

A proactive, prevention-first approach requires regular education and a strong culture of accountability.

Training Requirements

• All staff handling controlled substances should complete:
  • Initial training on DEA and clinic policies
  • Annual refreshers with updated protocols and case studies
• Include training on:
  • Recognizing red flags
  • Documentation requirements
  • Reporting procedures

Internal Policies

• Maintain a Controlled Substance Handling Policy that outlines:
  • Access permissions
  • Inventory protocols
  • Reporting requirements
• Require staff to sign acknowledgment forms yearly.

Double-Signing Policies

• Require two staff members to sign off on:
  • Disposal of expired or unused drugs
  • Reconciliation of inventory logs
  • Administration of high-risk drugs (e.g., fentanyl, hydromorphone)

Building a Security-Conscious Culture

• Conduct monthly briefings on diversion risks.
• Reward staff who spot inconsistencies or report concerns.
• Ensure leadership models secure and ethical behavior.