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HR’s Role in Drug Diversion Prevention: A Frontline That Often Goes Overlooked
Drug diversion remains one of the most persistent and costly challenges in healthcare. While clinical and pharmacy teams are typically at the center of prevention efforts, one critical function is consistently underutilized: Human Resources. Drug diversion begins earlier than the moment a controlled substance goes missing. It begins in the gaps between HR policy and operational practice, in the absence of pre-employment screening designed for this specific risk, in access permissions that were never reviewed, and in a workforce that was never trained to recognize the warning signs in a colleague. By the time an incident surfaces, the conditions that allowed it have usually been in place for months. Diversion prevention is rarely treated as an HR issue, and yet HR is far more central to that effort than most organizations recognize.
The Guidepost team works with health systems across the country on compliance program design and assessment, and we have seen this pattern repeatedly. HR is treated as a downstream function in diversion prevention, consulted after an incident rather than embedded in the structures meant to prevent one. That sequencing carries real consequences. The framework below, built around key compliance categories, offers a more practical and defensible way to think about HR’s role before a problem emerges.
Effective prevention begins long before an employee ever has access to controlled substances. Rigorous background screening is one of the most powerful tools HR has at its disposal, helping organizations confirm that the people they are bringing on have a demonstrated record of integrity. Regular drug testing keeps that commitment alive on an ongoing basis, sending a clear signal to staff and patients alike that the organization takes its obligations seriously. Together, these two practices form the foundation of a credible, defensible prevention program.
Access control is another area where HR’s role is frequently underestimated. Defining and enforcing who can interact with controlled substances and under what conditions is not simply a pharmacy or clinical decision. HR is essential to building the credentialing frameworks and policy structures that make access protocols consistent, auditable, and enforceable across the organization. When those structures are in place, accountability follows naturally.
What sets a truly mature prevention program apart, however, is how it handles the human element. Second chance programs designed and supported by HR provide structured pathways for employees who may be struggling, offering rehabilitation and intervention rather than immediate termination. This approach keeps the workforce healthy and aligned with the organization’s ethical standards, and it reflects a fundamental truth: organizations that invest in their people are better positioned to protect their patients.
Second chance programs, often referred to as Employee Assistance Programs (EAP) or peer support initiatives, can provide valuable rehabilitation pathways for employees facing substance misuse issues. However, it is critical that Human Resources play an active role in assessing the suitability of individuals for re-entry into the workplace, especially concerning their access to controlled substances. The decision to reinstate employees who have participated in these programs must involve careful evaluation of their progress and potential risks to public safety. This ensures that their return does not compromise the integrity of the healthcare setting or the safety of the substances handled. This balanced approach acknowledges the importance of supporting employees while prioritizing the responsibility to maintain public safety.
None of it works, though, without a culture that reinforces it. HR is uniquely positioned to lead the training and awareness efforts that bring diversion prevention to life at every level of the organization. When employees understand the risks, know the warning signs, and feel empowered to speak up, compliance shifts from a top-down mandate to a shared organizational value. That shift from obligation to culture is ultimately what makes prevention programs sustainable.
In June 2025, the Department of Justice announced what it described as the largest healthcare fraud enforcement action in the nation’s history, with charges filed against 324 defendants across 50 federal districts. The DEA’s posture has shifted, civil penalties are rising, and the reputational consequences of a diversion incident that becomes public are significant and lasting.
The Guidepost team approaches drug diversion compliance as a program design and assessment problem. That means examining how HR, pharmacy, compliance, nursing, and security function as an integrated system, and identifying where the gaps between policy and practice create real exposure. We have seen what effective programs look like and, more commonly, what gap-filled programs look like when they are stress-tested by an incident or an inspection. And when HR has a seat at the table, organizations are far better equipped to protect their patients, their people, and their practice.
MSU Institutional Assessment + RAMAGELLAN MonitorshipEmpire/Liberty Review