Combining Risk Mitigation Strategies for Maximum Protection

When it comes to controlled substance management, no single safeguard is enough on its own. Checking the PMP is important—but it won’t tell you if the patient is stockpiling medication. Urine drug testing is valuable—but it won’t reveal if a prescription was filled early at a different pharmacy. Pill counts help—but they’re only one snapshot in time.

The truth is, risk mitigation works best when it’s layered—like a security system with multiple points of defense.

The Core Risk Mitigation Tools

Here’s the foundation I recommend every practice put in place:

1. Prescription Monitoring Program (PMP) Checks – Every time, for every controlled prescription.
   
2. Controlled Substance Agreement (CSA) – Clear expectations, signed by the patient, reviewed annually.
   
3. Urine Drug Testing (UDT) – Baseline, random, and for-cause testing to verify compliance.
   
4. Pill Counts – Random and as-needed to detect misuse or diversion.
   
5. Visit Frequency Standards – Regular follow-up based on patient risk level, never exceeding 90 days.
   

Why Layering Matters

Think of each tool as a filter. Alone, each catches some risks—but not all. Together, they create a nearly airtight safety net.

Example:

• PMP catches a second prescriber.
  
• UDT catches undisclosed drug use.
  
• Pill count catches overuse.
  
• Visit frequency ensures ongoing monitoring.
  
• CSA sets the rules that make every step enforceable.
  

Miss one of these, and you leave a gap.

How to Implement Without Overwhelming Your Workflow

1. Automate Where Possible – Integrate PMP checks into your EHR so they’re run before you enter the room.
   
2. Standardize Policies – Write them down so every provider follows the same process.
   
3. Train Your Team – Staff should know their role in risk mitigation, from running reports to scheduling follow-ups.
   
4. Document Everything – If you don’t write it down, regulators assume it didn’t happen.
   

The Compliance and Legal Advantage

I’ve testified in multiple cases where providers avoided serious discipline not because they were perfect, but because they could show a consistent, multi-layered approach to risk mitigation. Regulators respect providers who can say:

“Here’s our protocol. We apply it to every patient, every time.”

It’s not just about protecting your license—it’s about improving patient safety and reducing the likelihood of harm.

Bottom Line

Controlled substance prescribing is one of the most heavily scrutinized areas in medicine. A single misstep can lead to devastating consequences. By combining PMP checks, CSAs, UDT, pill counts, and consistent follow-ups, you create a defensible system that protects both patients and your practice.

One safeguard is good. Five safeguards—done consistently—are almost bulletproof.

About the Author

Douglas J. Jorgensen, DO, CPC, FAAO, FACOFP

Dr. Doug is a physician, consultant, and national educator on medical documentation accuracy, patient engagement, and compliance strategy. He helps healthcare organizations develop systems that make patients active partners in their own medical records