How to Define Significant Loss (When the DEA Won't) — Plus Building a Diversion Program Across a Health SystemHow to Define Significant Loss (When the DEA Won't) — Plus Building a Diversion Program Across a Health System
Drug Diversion Insights with Terri Vidals
Two pharmacy leaders explain how they define "significant loss" of controlled substances and build a standardised diversion programme across a large, multi-state health system. Their conversation covers practical tools, education strategies and the importance of creating clear pathways for staff to raise concerns safely.
33:08•8 Jul 2026
Defining “Significant Loss” and Strengthening Drug Diversion Systems
Episode Overview
- A clear, written checklist helps define “significant loss” and avoids repeated debates over whether to report a controlled substance incident.
- Safety risk to the public, based on dose thresholds, is considered alongside percentages and volumes when deciding significance.
- Standardised algorithms and a 24/7 house supervisor role give staff a simple, consistent pathway to follow when diversion is suspected.
- Education focuses less on memorising details and more on knowing where to find procedures and who to contact in a crisis.
- Involving all key stakeholders and reducing siloed decision-making improves reporting, culture, and support for staff who need help.
“"People speaking up is one of the largest indicators we've found to really catch diversion."”
Understand the complexities of addiction with insights from two pharmacy leaders who spend their days trying to stop controlled substances from slipping through the cracks. This conversation centres on how a major health system tries to keep patients and staff safe while working within vague DEA rules. Host Terri Vidals chats with Calvin Parmiter, System Pharmacy Manager for Diversion and Compliance at WVU Medicine, and diversion coordinator Shannon Molnar.
Their health system spans 25 hospitals across four states, from busy academic centres to tiny critical access hospitals, so consistency is a constant challenge. A big focus is the DEA’s refusal to define what counts as a “significant loss” of a controlled drug.
Shannon explains how one incident pushed her to create a simple checklist so teams don’t spend "a four-hour discussion on whether this was significant or not every time something happened." She adds a safety lens too, asking, “Is there a possibility of harm due to the amount of controlled substance if found outside of our institution?” and using dose-based thresholds so anyone can work out when to report.
You’ll also hear how they structure a diversion programme across a health system. Calvin talks about standardising investigations and DEA compliance, while Shannon walks through practical tools like diversion algorithms, a 24/7 house supervisor as the first call, and a good old-fashioned notebook backed up by intranet documents. Education is key: new staff, charge nurses and supervisors are all taught where to go and who to call, rather than being expected to memorise complex procedures.
Perhaps the most relatable point for anyone in addiction and diversion work is Calvin’s reminder that "people speaking up is one of the largest indicators we've found to really catch diversion." If you work in healthcare or support recovery, this conversation might prompt you to ask: how easy is it for people in your setting to raise concerns and get a clear, confident response?
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