This blog post summarizes the key takeaways from Evan Frasure’s session at the 2026 Diversion Symposium. Evan provides a framework for turning the subjective nature of DEA regulations into an objective, repeatable process. To stream the session recording, click here.
From Gut Feelings to Algorithms: Solving the “Significant Loss” Puzzle
If you’ve ever stared at a missing vial of fentanyl or a discrepancy in oxycodone counts and wondered, “Is this significant enough to report?” — you aren’t alone.
The DEA intentionally avoids giving an exact number or percentage to define “significant loss.” Instead, they provide a list of factors to consider, such as quantity, drug type, and patterns of loss. While this flexibility helps different types of registrants (from manufacturers to small clinics), it creates a lot of anxiety for diversion experts.
In his session at the Bluesight Symposium, Evan shared how his organization replaced uncertainty with objective algorithms.
1. Defining “Significant Loss” Consistently
Consistency is your best defense. It reduces variability, builds confidence, and demonstrates due diligence to regulators. Evan recommends creating a standardized process that moves through four core questions:
- Does it meet the “Always Report” threshold? Set high internal thresholds (e.g., a full manufacturer package or a specific high quantity) that trigger an automatic report.
- Is the medication high-risk? Schedule II medications require tighter scrutiny than Schedule V.
- Are there concerning patterns? Does the loss happen every Monday? Is it always the same unit?
- What does your professional judgment say? This is the “gut check” conducted by a committee or an experienced individual familiar with local diversion trends.
2. Prioritizing Diversion Investigations
Most diversion teams have limited resources. You can’t perform a 90-day “deep dive” into every single analytics flag. You must prioritize based on risk.
Evan proposed an Investigation Trigger Algorithm to help determine when to move from a “shallow dive” (checking basic documentation) to a “deep dive” (full chart reviews, camera audits, and witness interviews).
Key Triggers for a Deep Dive:
- Impairment: Obvious signs of impairment at work.
- Patient Complaints: Patients reporting inadequate pain control specifically when a certain staff member is on duty.
- Analytics Outliers: A staff member with 50% more dispenses or 5x the waste volume compared to their peers.
- Behaviors: Taking medications off-campus (even accidentally) or volunteering for excessive overtime on high-acuity units.
3. The “Fitness for Duty” Decision
Once a deep dive confirms suspicious activity, the next algorithm determines if the employee needs a formal evaluation and drug screen.
Pro Tip: If you send an employee for a drug screen based on suspicion, the clock starts. Evan recommends submitting the 24-hour written notification to the DEA immediately. You then have 45 days to complete your investigation and submit the formal 106 form—or rescind the notification if the suspicion is cleared.
4. Implementing a Scoring System
To remove even more subjectivity, consider a point-based scoring system for audits. High-risk actions (like wasting a full package without a witness) get more points than “sloppy practice” (like forgetting to document a pain score). If an audit exceeds a certain score, it automatically escalates to the compliance committee.
Key Takeaways for Your Institution
- Standardize Your Definitions: Work with legal to decide your “Always Report” levels.
- Document the “Why”: Even if you decide a loss is not significant, document the logic you used to reach that conclusion. If the DEA audits you two years later, you’ll have the evidence of your decision-making process.
- Audit Your Own Process: Regularly check if staff know how to report losses and if your documentation is complete.
How does your organization handle the gray area of significant loss? Do you use a committee-based approach or a specific threshold?