Watch Out! Work Plans Are Coming!

You may not have October circled on your calendar just yet—but inside DEA Diversion groups across the country, it’s looming on the horizon. Why? Because October 1 marks the start of the government’s Fiscal Year 2026 – along with the year’s new Diversion Annual Work Plans. These plans are the agency’s way of saying: “Here’s a list of places we’re investigating and inspecting. Ready or not…here we come!” 

What’s a Work Plan?

Each year, every DEA Diversion Investigator (DI) around the country receives a work plan from their supervisor. It lists inspections and site visits that must be completed before September 30 of the following year (so, plans launched October 1, 2025 are finished by September 20, 2026).  Targets on the plans can include:

• Pharmacies
• Hospitals and clinics
• Narcotic treatment programs
• Manufacturers and distributors
• Importers, exporters, and reverse distributors
• Chemical companies

...and almost any registrant that’s landed on DEA’s radar for one reason or another

There’s no set number of sites on the plans. Some inspections are required by policy—like those for manufacturers, distributors, and narcotic treatment programs that are on a scheduled cycle. Others are hand-picked by Diversion group supervisors based on criteria such as: 

• Past violations or sanctions imposed by state licensing boards
• High numbers of controlled substance thefts or losses (remember those DEA Form 106s?)
• Suspicious controlled substance purchasing patterns
• Public complaints, bad press, or...well, general shadiness

And if you’re wondering if you can get a copy of the plans – nope – they’re confidential. You won’t know you’re on the plan until someone shows up at your door. Once you're on that plan, you’re not coming off.  The only way out is to go through—surviving the in-depth inspection that’s in your future.

Can You Stay Off the Work Plan?  

Let’s be honest: You can’t always control who at DEA will take an interest in your practice, pharmacy, or business.  But you can reduce your odds of showing up on DEA’s short list with a few proactive steps:

Handle State Board Issues Promptly

If you’ve had a run-in with, for example, your state pharmacy or medical board, deal with it quickly and document how you fixed the problem(s). DEA and state boards swap information —and red flags in one system tend to find their way into the other. 

Monitor Controlled Substance Losses

Excessive losses or frequent thefts of controlled substances in your practice or business are a flashing sign saying “INSPECT ME!”. If you’re a “frequent flyer” when it comes to filing DEA Form 106s, make sure your documentation shows how you investigated and corrected any issues of concern. Better yet, be proactive and implement changes that make repeat incidents less likely—and be ready to prove it.a

Know What Distributors Are Saying About You

Distributors are required to submit suspicious order reports (SORs) to DEA. If your order patterns (too frequent, too large, or other irregular behavior) trigger concerns, your supplier may quietly flag it—and now you’re under the microscope. If your distributor raises concerns with you directly, take them seriously and resolve them.

The most common way DEA gets tips about who to investigate? From unhappy humans. Disgruntled employees, competitors, frustrated customers, or pissed off ex-spouses have all “lit the fuse” on past cases. You can’t stop someone from calling in a tip—but you can control the narrative by running a tight, compliant, well-documented operation.

What’s Coming and When?

DEA Diversion groups are in the third quarter of FY 2025. That means over the next few months supervisors will gather team input, run database searches, and scour other information sources to build their lists for FY 2026. DEA headquarters may also issue directives—like “X number of inspections for narcotic treatment programs” or “re-inspect previously cited pharmacies”—which get baked into the plans. Before the end of September those target lists are finalized in time for the new work plans to kick off in October. And yes—these plans are part of Diversion Investigators’ performance reviews, so assignments are tracked and results are monitored throughout the year. 


Final Thought: Be Proactive, Not Panicked

If you’re reading this and worrying, “Could I be on the list?”—you might already be halfway to the answer.

But don’t panic. This is your chance to get ahead of any challenging situations, clean up your documentation, double check your security, and train your staff on the right ways for dealing with controlled substances.  (HINT:  Find your weak points by taking the TITAN Group’s Risk Assessment – FREE OF CHARGE!)

Remember:  most DEA registrants’ problems don’t start with some made-for-TV dramatic surprise. They start with an investigator walking in with a clipboard and saying “Let’s go over your records…”

And if you want to give those investigators a reason to be impressed—not alarmed – call TITAN today and we’ll get you ready for that knock on the door.