Common Regulatory Deficiencies of Hospital Employee Diversion September 27, 2026 By Larry K. Houck —

https://www.thefdalawblog.com/2026/09/common-regulatory-deficiencies-of-hospital-employee-diversion/?utm_source=rss&utm_medium=rss&utm_campaign=common-regulatory-deficiencies-of-hospital-employee-diversion The Controlled Substances Act (“CSA”) and Drug Enforcement Administration (“DEA”) regulations mandate legitimate handlers of controlled substances to obtain a DEA registration, create and maintain certain controlled substance records and reports, and implement effective security to guard against diversion. The underlying purpose of those requirements is to ensure controlled substance accountability by registrants. High profile, large-scale hospital and healthcare system employee diversion has been a recent theme in our FDA Law Blog posts (here and here). A number of common deficiencies were present in most or all of those cases. And while the cases involve hospital and healthcare diversion, the deficiencies are also found in employee diversion from pharmacies, physicians, dentists and veterinarians. The common deficiencies for employee hospital diversion cases include: