Today's Veterinary Business

AUG 2018

Today’s Veterinary Business provides information and resources designed to help veterinarians and office management improve the financial performance of their practices, allowing them to increase the level of patient care and client service.

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10 Today's Veterinary Business Business Business SECURITY 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 pat- tern 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 ac- counts with delivery address- es other than the practice location. Risk Factors The best defense against internal theft can start with answers to these questions: • Have thorough background checks been conducted on all employees at your hospi- tal? Were they administered a standard seven-panel drug urine test for marijuana, co- caine, opiates, PCP, amphet- amines, benzodiazepines and barbiturates? • Does your clinic have an up-to-date controlled sub- stance policy and procedure manual for establishing and maintaining effective anti-diversion controls? • Do you have video surveil- lance 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. Jack Teitelman is the founder and president of Titan Group, a regulatory com- pliance, drug security and anti-diversion solutions provider. He is a retired U.S. Drug Enforcement Administration supervisory special agent. 4 Train your employees. Does your practice have a stan- dard operating procedures manual? Does the manual spell out a policy of perform- ing a background investiga- tion and drug screening of each new employee? Advise employees that the consequence of theft can be termination. In addi- tion, the theft of controlled substances is a federally indictable offense and the potential losses might include a license revoca- tion, a financial loss and the damaged reputation of the individual and organization. Review your systems. How sure are you that the con- trolled substances kept at your hospital are secure and that your procedures meet the requirements of the DEA Controlled Substances Act? Ensure that your se- curity 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, vi- able veterinary business even harder. Having an action plan that empowers you to respond quick- ly, 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." Who Works for You? Free time is a rare commodity in veterinary medicine. In addition to being overworked and overextend- ed, 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 con- sider 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 ne- cessity 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 proce- dures, you are placing the practice and your livelihood at risk of criminal exposure and potential fines. I also recommend random drug screening of employees. 1 2 3

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