Where’s The Line? Objectivity in Determining Diversion or Significant Loss

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 2026 Diversion Symposium, Evan Frasure shared how his organization replaced uncertainty with objective algorithms.