It's no secret controls are one of the biggest subjects of any inspection, so if your pharmacy doesn't have a good handle on them it's time to start!
One thing I've heard pharmacists say before, when companies set new rules in place for controls, is --- "Don't they trust me?"
The answer to that question please .... (drum roll) ...
Nor should they.
In fact, if you are a trustworthy person, having tight procedures with controlled substances protects you. Why? It makes it much less likely you would ever be accused of something you didn't do because of messy records or sloppy procedures that have lots of gaps in it. It is easier to argue your innocence when there's a clear paper trail.
Now that we have that out of the way, where should we start?
I like to break down the process of tracking and accounting for controlled substances into each step of 'processing,' for lack of better words, in the pharmacy - ordering, receiving, dispensing, and wasting.
During each of these steps there has been and is potential for diversion in pharmacies.
Here's an illustration of the whole process with an overview of ways to protect from diversion during each step:
Get separate usernames on your wholesaler's site
I don't know how many places I've walked in to that allow everyone to order off the same username. If you do that, then who ordered the last bottle of Xanax that just came in? What if it was ordered but didn't come in? What if multiple bottles go missing?
Even worse, what if you discover that over the past year bottles and invoices were missing when the drugs came in, so that you weren't able to catch it? You obviously need to know who did the ordering, but now you're up a creek without a paddle.
With only one common username there is zero individual accountability. Get separate usernames for all staff so there is individual accountability for ordering.
If possible, have your wholesaler restrict control ordering to pharmacists only
If anyone at McKesson is reading this, I'm calling you out for not allowing us to restrict access on McKesson Connect. Shame on you! I've asked more than once and you've told me no. Your programmers should be able to fix this easily.
For those with a wholesaler that can restrict ordering rights to certain usernames, why not limit the hands in the cookie jar and restrict all control ordering (C2-5) to pharmacists only? There will always be a pharmacist on duty to order those items at the end of the day, and it limits the opportunity to divert them.
Don't buy 500 count bottles of C-II's
So you thought you were a big boy and bought a 500 count bottle of Percocet and now you're missing a pill. Problem is, that bottle's been open for two weeks and is supposed to have 139 in it, and you have no idea when the pill went missing. Did it only come with 499? Was there a miscount? Did that float pharmacist you only hired once partake in it?
You'll never know now. Save yourself the headache and never buy 500 count bottles.
In the case that's all you can get (it happened to me once), if state law allows break them up into 100 count sections in vials as soon as it comes in (keep in mind, that now will need a one year beyond-use date). Sign off on it, seal them with tamper tape, and then back count each vial just like it's a stock bottle.
Require two signatures for all controls
Some pharmacies approach the separation of duty by not allowing the same individual who ordered the control to check them in. I personally think that's impractical for most pharmacies; what if the same pharmacist is working two days in a row? If you're only allowing pharmacists to order then you'll be stuck only allowing the technician to sign the controls in.
A better way is to require two individuals (with at least one being a pharmacist) to sign-off on the controls when they are received. Yes, one might be the same person that ordered them, but the second individual acts as a safeguard.
For obvious reasons, it shouldn't be the same two people checking them in each time, though.