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Run: Medication Diversion Investigation

Use this Medication Diversion Investigation template to document a suspected controlled-substance discrepancy, verify MARs and counts, interview witnesses, a...

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Investigation Scope and Case Intake

Suspected diversion event identified and dated critical (required)

Record the date/time the discrepancy or suspicious event was first identified and the medication(s) involved.

Investigation scope defined critical (required)

Select all areas included in the investigation.

Note (optional)

Immediate containment actions completed critical (required)

Verify immediate actions were taken to preserve evidence and reduce risk.

Yes No N/A

Medication Administration Record (MAR) Review

MAR entries match ordered doses for the review period critical (required)

Compare ordered doses, documented administrations, omissions, refusals, and holds for the affected medication(s).

Yes No N/A

Late entries, overrides, or unusual documentation patterns identified critical (required)

Look for repeated late charting, copied forward notes, unexplained voids, or inconsistent administration times.

Yes No N/A

PRN and waste documentation reviewed critical (required)

Verify PRN administrations, partial doses, and waste documentation are complete and consistent with policy.

Yes No N/A

MAR discrepancies summarized

Document any missing signatures, unexplained administrations, duplicate entries, or dose variances discovered during review.

Controlled Substance Count Verification

Shift-to-shift count records reviewed critical (required)

Verify count sheets, shift handoff counts, and perpetual inventory records for the affected medication(s).

Yes No N/A

Witnessed counts match documented inventory critical (required)

Confirm that two-person counts or witness signatures align with the actual on-hand quantity and documented transactions.

Yes No N/A

Variance amount documented critical (required)

Record the quantity variance identified during count reconciliation.

Note (optional)

Count reconciliation method documented

Describe how the count was reconciled, including timestamps, locations, and staff involved.

Witness Verification and Chain of Custody

Witness signatures verified for all required count events critical (required)

Confirm required witness signatures or initials are present for counts, wastes, returns, and discrepancies.

Yes No N/A

Witnesses independently confirmed the count or waste critical (required)

Interview witnesses to confirm they observed the count, waste, or transaction in real time rather than signing retrospectively.

Yes No N/A

Chain-of-custody gaps identified critical (required)

Determine whether any medication transfer, storage, access, or disposal step lacked traceable documentation.

Yes No N/A

Staff Interviews and Access Review

Primary staff member interviewed critical (required)

Document whether the staff member assigned to the affected medication, shift, or cart was interviewed.

Yes No N/A

Additional staff or witnesses interviewed critical (required)

Confirm interviews were completed with charge nurse, supervisor, witnesses, or other staff with relevant access or observations.

Yes No N/A

Access patterns reviewed for the affected medication storage area critical (required)

Review badge access, key control, cart access, or cabinet access logs where available.

Yes No N/A

Interview summary and key statements documented

Summarize relevant statements, inconsistencies, explanations, and any admissions or denials.

Pharmacy Follow-Up, Reporting, and Corrective Action

Pharmacy notified of discrepancy critical (required)

Confirm the dispensing pharmacy or consultant pharmacist was notified of the suspected diversion or count discrepancy.

Yes No N/A

Pharmacy response and recommendations documented

Record any pharmacy guidance regarding replacement supply, inventory review, reporting, or medication security controls.

Corrective actions assigned with owner and due date critical (required)

Document corrective actions such as retraining, access restriction, enhanced counts, policy review, or escalation to compliance/risk management.

Regulatory or internal reporting completed as required critical (required)

Verify reporting obligations were evaluated and completed according to facility policy, state law, and applicable controlled substance requirements.

Yes No N/A

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