Audits & Investigations

While the opioid epidemic continues, every provider in the drug supply chain has a duty to identify and report suspicious orders. Retail pharmacies in particular have been hit with a number of settlements in 2017 for failure to report suspicious prescribing. See Related Blog. Surprisingly, many pharmacies still do not have policies and procedures addressing

On September 27, 2017, a subsidiary of AmerisourceBergen – AmerisourceBergen Specialty Group (ABSG) – admitted to illegally distributing misbranded drugs.  ABSG agreed to pay $260 million to resolve criminal liability for distribution of oncology supportive drugs from a facility that was not registered with the FDA. During the hearing, federal agents from various federal branches

Last week, the U.S. Department of Justice announced the largest ever healthcare fraud enforcement action by the Medicare Fraud Strike Force. Fraud charges were filed against 115 licensed professionals and payment suspension actions were initiated against 259 providers. DOJ’s announcement.

A particular focus is on medical professionals involved in the excessive prescribing and distribution of

Data accumulated in CURES[1] is available to appropriate state and federal agencies, law enforcement, and regulatory boards for disciplinary, civil, or criminal purposes. But when should CURES be reviewed for such purposes? When a government suspects overprescribing? May it be used against a prescriber or a pharmacist when no controlled substances are involved in the

Last week, I wrote about Walgreen’s settlement with state and federal governments for unlawfully soliciting Medicare and Medicaid beneficiaries to enroll in its Prescription Savings Club.

However, OIG has finalized a final rule extending safe harbors related to coupons, rebates, and other rewards from a retailer if:

  • The reward is offered on equal terms available

Last month, the DOJ and other state governments entered into a settlement with Walgreens. The company was accused of unlawfully soliciting Medicare and Medicaid recipients to enroll in its “Prescription Savings Club,” which gave discounts on thousands of brand and generic drugs as well as a 10% rebate on all Walgreens branded products including household

A very brief overview of California Administrative Discipline process.

The moment an inspector from a licensing board (Medical Board, Dental Board, Board of Pharmacy) comes to your healthcare business, it is important to understand and always keep in mind what such visit can lead to. I cannot stress enough how many times we could have