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Case Study: Decision-Making for Drug Diversion, A Leadership Guide to Procuring a Drug Monitoring System — Medacist


UNIVERSITY OF LOUISVILLE HEALTH (UofL Health) is a fully integrated regional academic health system with five hospitals, four medical centers, nearly 200 physician practice locations, more than 700 providers, the Frazier Rehab Institute, and Brown Cancer Center.


UofL Health’s reputation is its most valuable asset and is directly related to the conduct of its officers and team members. Being on the leadership team brings a commitment to steward the integrity of the health system and ensure patient safety. These responsibilities are ever-present when developing and overseeing a drug diversion program. 

This case study examines executive decision-making regarding drug diversion at UofL Health. The study profiles Robert Fink, the chief pharmacy executive, who provided insight into leadership’s recent decision to purchase a system to elevate detection and eliminate diversion.

“We consider a single dose a loss, and we have no tolerance for not knowing where that dose went,” said Fink. “We are always in a mindful, vigilant state as we can’t have anyone impaired working with a patient. We will investigate every loss in an extremely fair and thorough way.”

The system-wide Drug Diversion Response Team at UofL Health has three components. The first is an executive committee comprising Fink; Shari Kretzschmer, senior vice president and chief nursing officer; and Shelly Denham, senior vice president of compliance, risk and audit services. The triad reviews each case, and at least two of three must be involved in any investigation to eliminate unilateral decisions.

Secondly, a broader diversion team exists managed by a nurse solely dedicated to investigations who reports to the pharmacy manager responsible for regulatory and accreditation compliance for the entire system. They are the daily users of the monitoring system, conducting audits and surveillance. If an investigation is needed, they collaborate with the pharmacy manager, nurse, and HR business partner at the specific location with oversight from the executive committee.

The third entity involves a large multidisciplinary committee comprised of physicians, nurses, pharmacists, and HR business partners from every location. They have insight into investigations and approve policies and procedures and quality assurance programs.

Each member of a diversion team brings a unique skill set and perspective to the overall program. Tom Miller, CEO of UofL Health is ultimately responsible for all controlled substances in the health system.

As head of pharmacy services, Fink quarterbacked the rigorous process to choose a drug diversion system, and together with the chief medical officer, made the final decision.


UofL health’s purpose is to provide a culture of exceptional care and achieve the highest standards of quality and safety. Mitigating drug diversion is critical to accomplishing the mission of the health system.The code of conduct at UofL Health provides the foundation for a diversion plan. It states when employees face an ethical dilemma, take action. Employees need to speak up if any suspect activity.

“We are fortunate to have a CEO with broad experience who understands the critical need to combat drug diversion,” said Fink. “Equally, he is a leader with high standards and zero tolerance for drug diversion. He expects a high level of accountability from everyone.”

Every day at UofL Health, the main objective is to target risk within the medication-use process and identify risk areas across the health system at every level of responsibility.


Drug diversion has a devastating effect on the entire health system and undermines every department.

Fentanyl and other powerful controlled substances are commonplace, allowing a potential diverter to take them. Issues such as imprecise documentation, failure to physically witness a coworker’s controlled substance waste, temporary storage of medications in unsecure locations, or failure to complete required paperwork can allow diversion to happen.

“For a Grand Rounds presentation, I researched fines levied against health systems from the DEA. Every fine had two commas in them, and as each one displayed, they set a new record amount because of their failures,” said Fink. “There are steep consequences for not solving challenges.”


The UofL Health leaders understood the growing prevalence of drug diversion in healthcare facilities and developed a road map to strengthen its tools to eliminate it. A key strategy included a more robust system to deliver actionable intelligence on the medication process.

The multidisciplinary community sought greater clarity and confidence in their decision-making and wanted intelligence and documentation to substantiate diversion activity. These factors and more led to look at several drug diversion monitoring solutions including RxAuditor Investigate. 

“There is no singular decision-maker on an incidence. We take a collaborative approach to investigate a case under the principles of trust and verify. This was the same approach when deciding on a system,” said Fink.

After an extensive search lasting months, they narrowed the field to three finalists. Undergoing further analysis to align with overall system needs, UofL Health selected RxAuditor Investigate from Medacist as their drug diversion monitoring solution of choice. The committee’s decision ultimately came down to Medacist excelling at: analytics, compatibility, high standards, flexibility, investigations, compliance, and cost-effectiveness.

However, before choosing the RxAuditor Investigate solution, leadership put Medacist through their paces to learn how it could support UofL Health. The selection phase involved leadership:

Assessing three in-depth presentations on functionality.

Scrutinizing a live demonstration utilizing a test hospital.

Ensuring that the reporting and dashboards worked for leadership.

Verifying that RxAuditor Investigate could interface with existing systems.

Validating the accuracy of data analytics.

“RxAuditor Investigate met our needs,” Fink said. “Medacist had the stronger record in drug diversion technology solutions.”

Medacist’s solutions currently protect 67% of the U.S. patient population and more than  

3 million clinicians across more than 2,000 facilities nationwide. They hold the only U.S. patent for drug diversion analytics.

The case study provides details on how Medacist met UofL Health’s measures that led to the contract. The criteria are a blueprint for other health systems when choosing a drug monitoring system.


“What put Medacist over the top was that relationships matter,” said Fink. “We were dealing 

with conflicting system priorities, and the team at Medacist were willing to work with us.  

Their professionalism spoke volumes. We can’t thank them enough for their flexibility.”

The team could see the savings stemming from lessening the time an employee spends in labor-intensive investigations and reducing expensive medication losses. The tool’s efficiencies make it cost-effective.

Specifically, auditing consistency translates into a data reduction of 70% and labor savings of 30-40 hours per month. RxAuditor Investigate came as one single expense with no additional fees for hardware, software, or support.


UofL Health underwent a series of technology reviews and changes across the enterprise in 2020. Many pharmacy automation platforms didn’t have a monitoring system, or installing one was cost-prohibitive. IT even looked at building a surveillance system when leadership stepped in and said to review vendors, and Medacist won the account.

Interfacing with existing systems at UofL Health was a prerequisite. Leadership wanted transparency and standardization — a packaged solution for other systems, pharmacy automation, electronic health records (EHR), and time and attendance.

“When it came to integrating with other systems, RxAuditor Investigate was the best-of-breed system for us,” said Fink. “The configuration with our pharmacy system works seamlessly.”


RxAuditor Investigate is powered by Medacist’s Genesis™ analytics platform. This detection engine powers machine learning algorithms developed to identify diversion through pattern recognition —confirmed by actual diversion events and enriched by multiple other data sources.

The team has access to role-based configurable dashboards to see an overall snapshot, care area, or at-risk individual.


With RxAuditor Investigate, the previous need to perform time-consuming manual audits is eliminated by incorporating autonomous diversion auditing by evaluation, scoring, and ranking of risk — thus reducing false positives and curating a targeted list of at-risk individuals.

“When we conduct investigations, we appoint a nurse dedicated to ensuring each step of our monitoring cycle is complete,” said Fink. “The nurse also manages the program for controlled substance compliance.”

If local law enforcement, DEA, or Boards of Pharmacy and Nursing are supporting an investigation at UofL Health, the team can readily retrieve reports and provide meticulous records for those agencies.


The concluding theme is that a high level of accountability occurs at UofL Health regarding drug diversion. A major reason is because RxAuditor Investigate helps safeguard patients and provides leadership with accurate information to act on diversion.

The system from Medacist is supporting leaders across the enterprise, streamlining operations to make the facilities more efficient. The diversion teams now access a comprehensive platform of analytics and tracking technology, saving time and reducing liability.

After the installation, Medacist conducted an in-service to members of the Drug Diversion Response Team. Leadership received positive feedback, and the staff was specifically pleased with the performance and transparency of the system. 

“It’s about hiring good people and giving them RxAuditor Investigate to do their job,” Fink said. 

“From start to finish, we are ensuring accountability.”

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