Tag Archives: usual course of professional practice

DEA Decisions: Evidence of “Red Flags” of Drug Diversion

On November 10, 2016, the DEA issued its final decision and order in the case against Jones Total Health Care Pharmacy, L.L.C. (“Jones Pharmacy”) and SND Health Care L.L.C. (“SND”). The Administrator ordered that the DEA deny Jones Pharmacy’s registration renewal application and also deny SND’s pending registration application. These orders were consistent with the … Continue Reading

DEA Decisions: In the Matter of Hoi Y. Kam, M.D.

In the Matter of Hoi Y. Kam, M.D. (October 22, 2013) In July 2011, the New York Department of Health revoked Dr. Hoi Kam’s medical license on the ground that he previously committed Medicaid fraud and had been excluded from the Medicaid program in 2006.  Three months later, however, the State’s Administrative Review Board (ARB) … Continue Reading

A Pharmacist’s Obligation: Corresponding Responsibility and Red Flags of Diversion

Corresponding responsibility is perhaps one of the most commonly misunderstood and/or (unfortunately) unknown concepts found in DEA’s regulations.  And yet, enforcement actions against pharmacies are most frequently initiated when a pharmacist fails to exercise his/her corresponding responsibility.  I have had countless conversations with practicing pharmacists who are either unfamiliar with the concept of a “corresponding … Continue Reading