Category Archives: Suspicious Order Reports

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DEA Administrator Overrules ALJ, Revokes Distributor Registration in Sweeping Decision

The Chronicles welcomes guest blogger Katea Ravega, a Q&B Health Law attorney. In a 308-page decision dated September 8, 2015, the new Acting Administrator of the DEA, Chuck Rosenberg, issued an Order revoking the DEA registration of wholesale distributor Masters Pharmaceuticals, Inc. (“Masters”). In doing so, the Administrator rejected the recommendation from DEA’s own Administrative … Continue Reading

Non-Suspicious is Suspicious: DEA Moved the Goal Post Again!

Just when you thought it was safe to have a robust order monitoring program to detect and report suspicious orders, DEA has moved the goal post.  In previous posts (here and here), we’ve talked about DEA’s “extra-regulatory” guidance on both suspicious orders and “due diligence”.  In late February-early March, the DEA held a hearing in … Continue Reading

Suspicious Order Monitoring – What’s Next?

Come join us at the 2014 HDMA Distribution Management Conference and Technology Expo.  Linden and I are excited to share our perspective on the latest developments in suspicious order monitoring and reporting.  As an added bonus, we will also be available for a post-presentation discussion to continue the conversation on this very important topic.  Yet … Continue Reading

Suspicious Order Monitoring

…to infinity and beyond! For years manufacturers and distributors have searched for the holy grail of DEA compliance – specific guidance from DEA on what actually constitutes a suspicious order.  The obvious source of assistance and the sole legal basis establishing the requirement to detect and report suspicious orders is found in DEA’s own regulations.  … Continue Reading
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