Twenty-Six Milliliters
At a five-veterinarian practice, the practice manager conducts a monthly controlled-substance audit. Over six weeks, 120 mL of hydromorphone was purchased and 94 mL was logged as dispensed or wasted, leaving 26 mL unaccounted for. Only three people have keys to the safe: the owner, the lead technician, a 20-year employee and close friend of the owner, and one associate veterinarian. The log contains two entries with correction fluid and no initials. There are no cameras in the treatment area. When the manager raises the discrepancy, the owner says, 'Don't blow this up. If it's Brenda, it will destroy her family. Just watch her and adjust the log.' A technician later mentions that Brenda seemed unusually drowsy last week. The manager has no written diversion policy.
1. What immediate actions should the manager take before accusing anyone, and why?
Read the worked answer
Contain and preserve first. Recount the remaining hydromorphone with a second person, seal and label what remains, and restrict access to the owner and one designated person. Do not alter or 'adjust' the log; photograph every page, preserve the correction-fluid entries, and start a written chain-of-custody record. Pull purchase invoices, dispensing records, waste witness signatures, and access-key records for the six-week period. Interview no one alone and make no accusation yet. Check whether the practice has a written policy; if not, the manager still has a duty to protect patients and staff. Separate the safety question from the disciplinary question: a drowsy employee handling controlled drugs is an immediate patient-safety risk and may need to be removed from drug duties while the investigation proceeds. Notify the practice's legal counsel and insurance carrier early. The goal is an accurate, documented record that can support either exculpation or reporting.
2. Explain the legal and ethical reporting obligations, including what the manager should do if the owner refuses to report.
Read the worked answer
In the United States, a DEA-registered practitioner must notify the DEA field division in writing within one business day of discovering a theft or significant loss of controlled substances; local law enforcement and the state veterinary board may also require notice. The practice should verify exact requirements with counsel, but 'watch her and adjust the log' is not a lawful option because it conceals a loss and creates false records. The manager's ethical duty is to patients, the public, and the profession, not to protect a colleague's family. If the owner refuses, the manager should put the concern in writing, cite the specific discrepancy and the owner's instruction, and ask for a written decision. The manager should not falsify the log or sign a false report. If the owner still refuses, the manager should escalate to counsel, the practice's insurer, or the appropriate regulator, and consider whether remaining in the role is tenable. Whistleblower protections vary, so legal advice is essential.
3. How should the manager communicate with the team and reduce future risk without destroying trust?
Read the worked answer
Communicate on a need-to-know basis: the team does not need the details, but they do need to know that access is restricted and that audits will continue. Avoid naming Brenda or speculating. If she is placed on leave or removed from drug duties, give a neutral explanation such as 'temporary change in responsibilities' and do not discuss the investigation. Offer an employee assistance program or impaired-professional resource if one exists. After the investigation, update policy: single-person access limits, witnessed waste, monthly reconciliation, random audits, and a no-blame reporting channel for discrepancies. Train everyone on the policy and sign acknowledgments. The goal is not to create a surveillance culture but to make diversion hard and reporting safe. Trust returns when staff see consistent rules applied to everyone, including long-tenured employees and owners.