Untangling the Intricacies of Suspicious Order Monitoring Requirements

May 29, 2019 10:30am

Cathy Gallagher
Senior Consultant, U.S. Compliance Solutions
IQVIA (Richmond, VA)

  • Aligning manufacturer and distributor obligations with DEA’s current stance
    • Masters and the aftermath: deciphering responsibilities related to chargeback data
    • Determining when to fill flagged potentially-suspicious orders
  • Enhancing your “Know Your Customer” and “Know Your Customer’s Customer” programs
    • Making proper adjustments to statistical analysis and algorithms to capture customer and expected downstream data
    • Bolstering internal pharmacy investigations
  • Update on DEA’s Suspicious Order Monitoring Guidance
    • Evaluating the interpretation of SOM requirements through final order without notice and comment rulemaking
    • Diving into recent DEA settlements related to failure to report suspicious orders