Supply Chain Due Diligence for Manufacturers and Distributors: A Deep Dive into Satisfying DEA Diversion Obligations and Streamlining Suspicious Order Monitoring

Hunter G. DeKoninck
Attorney
Quarles & Brady LLP

Cory Kopitzke
Assistant General Counsel, Regulatory
Cardinal Health

Todd Prough, Ph.D
Controlled Substance Monitoring Program
AmerisourceBergen
Former Head of Pharmaceutical Investigations, DEA

Sarah Pechnick
Senior Director
Guidepost Solutions
- Unpacking Suspicious Order Monitoring (SOMS) parameters:
- What exactly constitutes a “suspicious order” (SO) and a “order received under suspicious circumstances” (ORUSC) and what does that mean in practical terms for distributors
- Learning how to design and operate a system to identify SOs and ORUSCs
- What information must you include when you report a suspicious order or ORUSC to DEA?
- Understanding the benefits of an ERP system and knowing the legal and compliance aspects of utilizing technology to fulfill diversion obligations
- Training employees to comply with SOMS requirements
- Best practices for conducting virtual and onsite visits with prospective customers
- Knowing where to search for relevant information and knowing the right questions to ask
- Identifying the common and lesser-known red flags according to industry practice, legislative guidance and case law
- Considering the unique due diligence for international supply chains