Follow-Up Review of the Drug Enforcement Administration’s Efforts
to Control the Diversion of Controlled Pharmaceuticals

Evaluations and Inspections Report I-2006-004
July 2006
Office of the Inspector General

To reach the best estimate of time devoted by the DEA to pharmaceutical cases, we present two special agent and intelligence analyst work hour analyses based on two different data sets. The first analysis is based on “2000 series data” and is a measure of the time that that special agents and intelligence analysts spent assisting diversion investigations. The second analysis is based on G-DEP data and is a measure of all time spent on pharmaceutical investigations by special agents and intelligence analysts. Diversion investigations. Every DEA investigation has a unique case number consisting of eight digits that specify the (1) field division where it was initiated, (2) the fiscal year when it was initiated, and (3) who initiated it. Cases initiated by diversion investigators are denoted as “2000 series” cases. Pharmaceutical investigations. The G-DEP code is a five-character code the DEA assigns to all criminal investigations indicating (1) the type of investigative target, (2) whether other agencies are involved in the investigation, (3) the principal controlled substance or commodity involved in the investigation, and (4) the geographic scope of the criminal activity under investigation. There are 51 principal controlled substances captured by the G-DEP code. According to the DEA, 29 of a possible 51 substances related to the diversion of controlled pharmaceuticals; however, we concluded that only 15 were within the scope of this review. The 15 substances classified with a G-DEP identifier and included in our review are: Methylphenidate Fentanyl (and its generics) Ketamine (and its analogues) Opioid Treatment Pharmaceuticals Hydromorphone (Dilaudid) Schedule II Pharmaceutical Narcotic Schedule II Pharmaceutical Non-Narcotic Schedule III Narcotic Benzodiazepine All Other Pharmaceutical Controlled Substances Oxycodone Hydrocodone Palladone Steroid (pharmaceutical) Pharmaceutical Cocaine The remaining 14 of the 29 substances not included in our review (for reasons stated) are: Methaqualone – This is a schedule I drug not being legally manufactured or imported. GHB/GBL/BD (and other GHB analogues) – This is an active ingredient for one Schedule II pharmaceutical, but not a pharmaceutical. Unspecified Analogues – This is an ingredient in controlled pharmaceuticals, but not a pharmaceutical controlled substance. Amphetamine/Stimulant Related Chemical – This is a listed chemical, and thus, outside of our scope. Pseudo ephedrine – This is a listed chemical, and thus, outside of our scope. Ephedrine – This is a listed chemical, and thus, outside of our scope. Hallucinogen-Related Chemical – This is a listed chemical, and thus, outside of our scope. Iodine/Red Phosphorus – This is a listed chemical, and thus, outside of our scope. Depressant-Related Chemical – This refers to chemicals, and is thus, outside of our scope. Chemical Equipment (non-drug-specific) – Chemical equipment is not a controlled substance. Depressant (clandestine) – Clandestinely produced substances are not diverted drugs. Other Stimulant (clandestine) – Clandestinely produced substances are not diverted drugs. Steroid (clandestine) – Clandestinely produced substances are not diverted drugs. No Specific Drug – This code is used for controlled pharmaceuticals as well as illicit drugs. Comparison of “2000” series and G-DEP Work Hour Data. The DEA informed us that there is no perfect way to capture the entire universe of all pharmaceutical investigations. However, both of the methods we present – using “2000 series” case data and using G-DEP code data for the 15 principal controlled substances within the scope of our review – have advantages and disadvantages, as described in Table 1. Table 1. Comparison of “2000 Series” and G-DEP Work Hour Data   “2000 Series” Data G-DEP Data Basis for data Based on an investigation’s case number. The “2000 Series” data represents investigations initiated by diversion investigators. Based on the G-DEP substance identifier of investigation. We concluded that there were 15 principal controlled substances captured by the G-DEP code that were within the scope of our review. Time period of data Data is available for the entire review period, FY 2002 – FY 2003. Data is only available for FY 2003 – FY 2005.* Substances included in analysis All cases initiated by diversion investigators are captured, regardless of the controlled substance involved. The identifier allows for analysis of specific substances. Diversion cases on substances not selected are not captured. Disadvantages of data set Pharmaceutical investigations initiated by special agents are not captured. Chemical diversion investigations outside the scope of our review are captured. Deciding which of the 51 substance identifiers to include is subjective. Time spent on non-criminal diversion investigations is not captured because only criminal cases are assigned G-DEP codes. The identifier for the substance only indicates the lead drug and is sometimes changed during the investigation. * Because the DEA restructured the list of principal controlled substances or commodities in 2002, FY 2002 data based on the G-DEP code is not comparable to more recent data, and our analysis of G-DEP data covers only FY 2003 through FY 2005.