Purpose Statement

Controlled substance occurrence issues in First Due alert supervisors and field personnel when a medication count discrepancy is detected during routine counting procedures. This visual notification system ensures immediate awareness of count failures, maintains regulatory compliance with DEA requirements, and creates an auditable trail of all controlled substance discrepancies. Understanding how to identify, interpret, and resolve occurrence issues is critical for maintaining accurate medication inventory and meeting federal controlled substance tracking standards.

Background Information

An Occurrence Issue is automatically generated by First Due when a controlled substance count reveals fewer medications than were documented in the previous count. For example, if a med kit was last counted with 3 vials of Fentanyl but the current count shows only 2 vials, the system creates an occurrence to flag this discrepancy. This automated detection system serves multiple purposes: it alerts supervisors to potential compliance issues, creates documentation for DEA audits, maintains chain of custody integrity, and prompts field personnel to document the reason for missing controlled substances.

Occurrences can result from several scenarios including medications used on patients but not documented, controlled substances transferred to another kit without proper logging, medications removed due to damage or expiration, or simple counting errors during the initial count. The system differentiates between agencies tracking individual serial numbers (which can identify the exact missing medication) and those tracking only lot numbers (which shows the quantity missing from a specific lot).

All occurrence issues are documented in the Medication Log and appear in generated PDF log books, ensuring complete compliance with DEA record-keeping requirements and providing comprehensive audit trails for regulatory reviews.

Required Permissions

To view, manage, and resolve controlled substance occurrence issues, users must have the following First Due permissions enabled:

Viewing Occurrence Issues:

• Med Kits
• Medication Dashboard
• Medication Log

Resolving Occurrence Issues:

• Count Medications
• Meds - Usage
• Transfer Medications
• Remove Medications
• Meds - Custody Exchange
• Medication Signature
• View Seal Numbers

Field personnel typically require all of these permissions to perform daily medication management tasks and resolve discrepancies as they occur. Supervisors and medication coordinators should have access to the Medication Dashboard and Medication Log to monitor occurrences and generate compliance reports.

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Step-by-Step Guide

Step 1: Identifying an Occurrence Issue Visually

When you navigate to the Med Kits section after completing a count with a controlled substance discrepancy, the occurrence issue appears with distinct visual indicators:

Visual Appearance:

• Red "X" icon next to the medication name
• "Occurrence issue" label in red text
• CS (Controlled Substance) badge displayed
• Expiration date visible
• Number of units affected shown

What This Means: The occurrence issue indicates that during the most recent count, the system detected fewer controlled substances than were documented in the previous count. The medication remains flagged with this visual indicator until corrective action is taken and a new count verifies the accurate inventory.

Serial Number vs. Lot Number Tracking:

• Serial Number Tracking: If your agency tracks individual serial numbers, the occurrence will identify the exact missing medication by its unique serial number
• Lot Number Tracking: If your agency tracks only lot numbers, the occurrence will show the quantity missing from a specific lot (e.g., "3 items from Lot ABC123 missing") but cannot identify which specific medications are absent

Step 2: How an Occurrence Happens and Supervisor Notification

Occurrence Creation Process:

1. Field personnel perform a medication count on their assigned med kit
2. During the count process, they verify the physical seal number and enter it into the system
3. They select "Break and Count" to begin counting medications

1. When counting controlled substances, they mark each medication present with a thumbs up or mark missing medications with an X
2. Upon completing the count and providing required signatures, the system compares current counts to previous counts
3. If a controlled substance shows fewer units than the previous count, an occurrence is automatically created
4. The occurrence appears immediately with the red X visual indicator
   
5. Users will complete the dual signature process to log the event and trigger the occurrence issue

Supervisor Notification:

Supervisors are notified of controlled substance occurrence issues through multiple channels:

• Email Notification: Supervisors receive an automated email alert when an occurrence is created, containing medication details, unit/apparatus information, and the personnel who performed the count

• Medication Dashboard: The occurrence appears on the Medication Dashboard by going to completed counts and finding the corresponding count that generated the occurrence.

• Med Log View: Supervisors can access the Medication Log where occurrence issues are highlighted in red with "Count-failed" labeling for easy identification. Select the Eyeball icon to view specific occurrence or event information.

The supervisor can click the eyeball icon in the Med Log to view detailed information about the occurrence, including who performed the count, when it occurred, which specific medication is affected, and any subsequent corrective actions taken.

Step 3: Resolving Occurrence Issues

Occurrence issues can be resolved through three primary methods depending on what actually happened to the missing controlled substance. Best practice is to use the Multi-Action workflow on the desktop version of First Due to document the corrective action and perform a count simultaneously.

Resolution Method 1: Document Usage (When Medication Was Used But Not Logged)

Use this method when the controlled substance was administered to a patient but the usage was not properly documented in the system.

1. From the Med Kits overview, click Usage
2. Find the medication that was used and select the down arrow to show available lot numbers or serial numbers
3. Select the appropriate lot number or serial number that matches the medication that was actually used
4. Click the arrow icon to move it into the Usage column
5. Enter the number of medications used
6. Document if there was any waste
7. Select the specific serial number if tracking individual medications
8. Use the Add Action menu to add a Count action (Multi-Action workflow)
9. Click Count to begin the counting process
10. Confirm the Multi-Action flow message and click Continue
11. Click OK to proceed
12. Count all medications in the kit, marking present medications with thumbs up
13. Click Sign and Finish
14. Enter the new seal number and click Add seal
15. Click Sign and enter your password
16. Provide your signature and click Save

After completing this workflow, the occurrence issue will be cleared from the system because the usage has been documented and a new accurate count has been performed.

Resolution Method 2: Document Transfer (When Medication Was Moved to Another Kit)

Use this method when the controlled substance was transferred to another med kit or medication supply but the transfer was not properly documented.

1. From the Med Kits overview, navigate to the medication transfer workflow
2. Select the source kit where the medication is missing
3. Select the destination kit or medication supply where the medication was actually transferred
4. Identify the specific lot number or serial number that was transferred
5. Document the quantity transferred
6. Use the Add Action menu to add a Count action (Multi-Action workflow)
7. Complete the count process following the same signature and seal procedures outlined in Resolution Method 1

The occurrence will be cleared once the transfer is documented and a new count verifies the accurate remaining inventory in the source kit.

Resolution Method 3: Document Removal (When Medication Is Actually Missing or Damaged)

Use this method when the controlled substance is truly missing, damaged, expired, or otherwise needs to be removed from inventory with documentation for DEA compliance.

1. From the Med Kits overview, click Remove
2. Find the medication that needs to be removed and select the down arrow to show all available lot numbers or serial numbers in that med pouch
3. Select the appropriate medication to remove
4. Click the arrow icon to move it into the Remove column
5. Select the specific serial number that is missing
6. Click Reason to document why the medication is being removed
7. Select the appropriate reason from the dropdown (e.g., "Missing," "Damaged," "Expired")
8. Type additional details in the reason field explaining the circumstances
9. Use the Add Action menu to add a Count action (Multi-Action workflow)
10. Complete the count process
11. Provide both primary and witness signatures as required for controlled substance removal
12. Click Sign and Finish
13. Enter your password and provide your signature
14. The witness (USER2) must select their name from the dropdown, enter their password, and provide their signature
15. Click Save to complete the removal and count

After documenting the removal with proper reason and signatures, the occurrence is cleared and the removal is permanently recorded in the Med Log for compliance purposes.

Resolution Method 4: Perform Re-Count (When Original Count Was Entered Incorrectly)

If the occurrence was created due to a simple data entry error during the original count:

1. From the Med Kits overview, click Count
2. Verify the physical seal number and enter it into the system
3. Click Add seal and Save
4. Click Break and Count
5. Carefully count all medications, paying special attention to the medication flagged with an occurrence
6. Mark all present medications with thumbs up
7. Complete the signature and seal process

If the re-count shows the correct number of medications (matching the expected count), the occurrence will be automatically cleared because the system recognizes the counts now match.

Best Practice: Using Multi-Action Workflow

The Multi-Action workflow is the recommended method for resolving occurrence issues because it allows you to:

• Document the corrective action (Usage, Transfer, or Remove) and perform a count in a single workflow
• Sign all actions at once at the end rather than signing multiple times
• Reduce the risk of creating additional discrepancies
• Streamline the resolution process for efficiency

Multi-Action is only available on the desktop version of First Due, so supervisors and medication coordinators should use desktop computers when resolving complex occurrence issues.

Step 4: Auditing and Generating Compliance Reports for Occurrences

Supervisors and medication coordinators need to audit occurrence issues for compliance tracking, DEA reporting, and investigation purposes. First Due provides a comprehensive audit workflow through the Medication Log.

Accessing Occurrence Audit Information:

1. From the First Due main menu, click Medications
2. Click Med Log to access the Medication Log view
3. Scroll through the log to locate occurrence issues, which are highlighted in red with "Count-failed" status labels for easy identification
   
4. Click on the occurrence entry you want to audit
   
5. Review the occurrence details displayed including:
   
1. Medication name and type
   
2. Date and time the occurrence was created
   
3. Personnel who performed the count
   
4. Expected vs. actual count
   
5. Serial number or lot number affected
   

1. Click the eyeball icon to view detailed information about the occurrence
   

Generating Detailed PDF Log for Investigation and Compliance:

7. Select the occurrence event by clicking the checkbox next to the occurrence entry
8. Select any subsequent events related to the occurrence resolution (usage, transfer, removal, or follow-up count) by clicking their checkboxes
9. Click Bulk Actions at the top of the Med Log
10. From the dropdown menu, select Detailed Log
11. The system will generate a comprehensive PDF report containing:
• Complete timeline of the occurrence from creation to resolution
• All personnel involved with signatures
• Detailed medication information including serial/lot numbers
• Reasons and explanations for any corrective actions
• Verification count results
• Timestamps for all activities
  
12. Save or print the PDF for your records, DEA audits, or internal investigation files

Using Detailed Logs for Compliance:

• Generate detailed logs immediately when investigating unexplained occurrences
• Keep PDF logs readily available for regulatory inspections
• Review occurrence patterns monthly to identify training needs or process improvements
• Include occurrence documentation in controlled substance audit files
• Share relevant logs with administration during compliance reviews

This audit workflow ensures complete documentation of all controlled substance discrepancies and demonstrates your agency's accountability to regulatory requirements.

Best Practices

Immediate Response to Occurrences:

• Address occurrence issues as soon as they are identified
• Do not delay resolution as occurrences represent potential compliance violations
• Contact your supervisor immediately if you discover an occurrence you cannot explain

Accurate Documentation:

• Always provide detailed explanations in the reason field when removing medications
• Be specific about circumstances (e.g., "Vial found broken in med kit during shift check at 0800")
• Include serial numbers or lot numbers whenever possible for complete traceability

Use Multi-Action Workflow:

• Whenever possible, use the desktop version of First Due to access Multi-Action workflows
• This reduces the number of steps and minimizes the risk of creating additional discrepancies
• Multi-Action ensures all corrective actions and verification counts are signed together

Double-Check Count Accuracy:

• Always count controlled substances twice before submitting to avoid creating unnecessary occurrences
• Have a partner verify your count whenever possible, especially for high-value medications
• Take your time during counts rather than rushing through the process

Serial Number vs. Lot Number Awareness:

• Know whether your agency tracks serial numbers or lot numbers
• If tracking serial numbers, always verify you're documenting the correct specific medication
• If tracking lot numbers, be aware that the system cannot identify which specific item is missing

Supervisor Review:

• Supervisors should review all occurrence issues daily through the Medication Dashboard
• Check Med Log regularly for patterns that might indicate training needs or process issues
• Generate PDF log books regularly for compliance documentation and audits

DEA Compliance:

• Treat all controlled substance occurrence issues as compliance matters requiring documentation
• Maintain accurate records of all corrective actions taken
• Ensure removal reasons are specific and defensible for regulatory review
• Keep PDF log books readily available for inspections and audits

Communication:

• Notify your supervisor verbally when an occurrence is created, even though they receive email notification
• Discuss unclear situations before documenting removal reasons
• Share lessons learned from occurrences with your team to prevent future issues

Troubleshooting & FAQs

Q: I completed a usage and count to clear an occurrence, but the red X is still showing. What should I do?

A: Ensure you completed all steps including the final count and signatures. The occurrence only clears once a new count is successfully completed and signed. If the issue persists after completing all steps, check that the usage or removal you documented was for the correct serial number or lot number. Contact your medication coordinator if the occurrence remains after verification.

Q: What happens if I can't explain why a controlled substance is missing?

A: Document a removal with the reason "Missing" and provide as much detail as possible about when you discovered the discrepancy. Notify your supervisor immediately. Your agency may have additional investigation protocols for unexplained controlled substance losses. All occurrences are tracked in the system for compliance and audit purposes.

Q: Can I resolve an occurrence from the mobile app?

A: Yes, you can resolve occurrences from the mobile app by documenting usage, transfer, or removal followed by a count. However, the Multi-Action workflow (which is more efficient) is only available on the desktop version of First Due. For complex situations, supervisors recommend using a desktop computer.

Q: How long do occurrence issues stay in the system?

A: Occurrence issues remain visible with the red X indicator until they are resolved through proper documentation (usage, transfer, removal, or corrective count). Once resolved, the occurrence documentation remains permanently in the Med Log and PDF log books for compliance purposes, but the red X visual indicator is removed.

Q: What if I create an occurrence by mistake during counting?

A: Simply perform another count immediately. If you accidentally marked a medication as missing when it was actually present, the next count showing the correct number will clear the occurrence. However, the occurrence will still appear in the Med Log as part of the audit trail.

Q: Do occurrences affect my ability to perform custody exchanges?

A: No, occurrence issues do not prevent custody exchanges. However, best practice is to resolve occurrences before performing a custody exchange so the receiving personnel start their shift with accurate inventory. Both parties should be aware of any unresolved occurrences during the exchange process.

Q: What's the difference between an occurrence and a missing medication?

A: An occurrence is the system notification that a count discrepancy has been detected. A missing medication is one of several possible reasons for an occurrence. Other reasons include unreported usage, undocumented transfers, or counting errors. The occurrence is the alert; the investigation determines the actual reason.

Q: Can supervisors see who created an occurrence?

A: Yes, supervisors can view complete details about occurrences including who performed the count that created the occurrence, the date and time, which specific medication is affected, and all subsequent actions taken to resolve it. This information is available in the Med Log detail view.

Q: How do occurrence issues appear in PDF log books for audits?

A: Occurrence issues are highlighted in PDF log books with the same red visual indicators seen in the system interface. The PDF shows the original count that created the occurrence, the "Count-failed" status, and all corrective actions taken including usage documentation, transfers, or removals. This provides a complete audit trail for DEA inspections.

Q: What if multiple occurrences exist on the same medication?

A: Each occurrence must be resolved individually. If you have multiple occurrences for the same medication, work backwards from the most recent to understand what happened. You may need to document multiple usage events, transfers, or removals. Contact your supervisor for guidance on resolving complex occurrence patterns.

Q: Are witnesses required for all occurrence resolutions?

A: Witness signatures are typically required for controlled substance removal actions. Usage and transfer actions may require witness signatures depending on your agency's policies. Check with your medication coordinator about specific witness requirements for your department.

Q: Can I delete or hide an occurrence?

A: No, occurrences cannot be deleted from the system. They are part of the permanent controlled substance audit trail required for DEA compliance. Once an occurrence is created, it can only be resolved through proper documentation, not removed from the record.

Additional Considerations

DEA Compliance and Audit Trail Documentation

All controlled substance occurrence issues create permanent entries in First Due's audit trail system that cannot be deleted or modified. This comprehensive documentation meets DEA requirements for controlled substance tracking and provides complete chain of custody records. When generating detailed Med Logs for regulatory inspections, occurrence issues appear with:

• Timestamp of when the occurrence was created
• Personnel who performed the count that identified the discrepancy
• Medication name, lot number, and serial number (if applicable)
• Expected quantity vs. actual counted quantity
• All corrective actions taken including usage, transfer, or removal documentation
• Signatures of all personnel involved in resolution
• Final verification count that cleared the occurrence

Screenshot placeholder: Detailed Med Log PDF showing occurrence documentation and resolution trail

Keep PDF log books readily accessible for DEA inspections, as occurrence documentation demonstrates your agency's commitment to controlled substance accountability and compliance with federal tracking requirements.

Serial Number Tracking vs. Lot Number Tracking

The level of detail in occurrence issues depends on your agency's tracking method:

Serial Number Tracking:

• Identifies the exact missing medication by unique serial number
• Provides precise documentation for which specific vial, ampule, or unit is missing
• Required by some agencies for high-value or high-risk controlled substances
• Enables more detailed audit trails and investigation capabilities

Lot Number Tracking:

• Shows quantity missing from a specific lot (e.g., "2 units from Lot XYZ123")
• Cannot identify which specific medications within that lot are missing
• Sufficient for many agencies' compliance requirements
• Less administrative burden but reduced investigation granularity

Understanding your agency's tracking method helps you provide appropriate documentation when resolving occurrence issues.