Untangling the Intricacies of Suspicious Order Monitoring Requirements
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