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AICPA

Barbara Rowland Presents on DEA Enforcement Actions and Using Data to Protect Against Diversion at ASPL's Developments in Pharmacy Law Seminar on Nov. 3


On November 3, 2017, Barbara Rowland, Principal and Washington, D.C. Chair of the White Collar Practice Group, presented "The DEA Is Here to Stay: Recent Enforcement Actions and Using Your Own Data to Protect Against Diversion," at the American Society for Pharmacy Law's (ASPL) Developments in Pharmacy Law Seminar in Scottsdale, AZ.

In 2016 and 2107, the Drug Enforcement Administration (DEA) continued its industry-wide enforcement actions against wholesalers and large pharmacy companies that distribute and dispense controlled substances regulated under the Controlled Substances Act. Since 2013, over $300 million in fines and penalties under the Controlled Substances Act were recovered, including record-setting settlements with major retailers and distributors.

The presentation covered recent federal enforcement trends of the Department of Justice and DEA and the challenges presented to pharmacies and wholesalers. The presenters discussed both typical and evolving red flag metrics targeted by DEA and how metrics may reflect patterns of ordering, prescribing, and dispensing that can be aligned with either diversion or legitimate business practices and, in some instances, both. They also discussed actions that pharmacies and wholesalers can take using their own data and compliance practices to proactively identify and address risk