A DEA diversion investigation does not usually start with a tip. It usually starts with a discrepancy — an inventory anomaly, a witness-signature gap, an administration record that does not reconcile to a waste record. A routine cycle inspection becomes something else.
Under the PPAEMA Final Rule, EMS agencies are now subject to the same diversion investigation playbook that has applied to hospitals and pharmacies for decades. The records pulled in the first 48 hours are predictable. The deficiencies that escalate a routine review into a formal investigation are predictable. This post translates field-reported patterns into a defensive checklist.
This is not legal advice. It is a recordkeeping posture every agency should be able to defend. Read More >
