McKesson Corporation


Industry: Pharmaceuticals
Underlying Misconduct: Other
Matter Type: DOJ Civil
Relevant Jurisdiction(s): Washington, DC
Penalties: Civil Penalties
Fine Amount: $150,000,000
Reporting Agencies: Drug Enforcement Administration
Resolution Form: Settlement Agreement
Agreement Date: January 17, 2017
Monitor Reference Term: Independent Review Organization
Monitor Identity: Unknown
Monitorship Term: 5 Years
Monitor Selection Process:

Host Organization to provide 3 candidates from which Reporting Agency selects.

Time to Propose Monitors: 60 days
Time to Engage Monitor: 120 days
Time to First Report:
Reporting Frequency: Annually
Monitor Required Qualifications:

Employs or retains personnel with adequate experience and expertise related to the pharmaceutical industry, the distribution of controlled substances, and the applicable requirements of the CSA and DEA's implementing regulations. Shall also have personnel with expertise in the audit and review of sample documents in order to conduct required reviews. Must perform reviews in a professionally independent and objective fashion, as defined in the most recent Gov't Auditing Standards. Ethical walls may be established if Monitor has previously performed work for Host Organization and/or may be expected to perform work for Host Organization during term of Agreement.

Summary of Monitor's Scope:

Conduct following reviews: Threshold Change Request Review; Onboarding New Customer Review; Event Triggered Due Diligence Review; Incentive Compensation Review.

Summary of Monitor's Activities:

Please see Agreement for further details. Activities could be more construed as "audits" than Corporate Monitoring, as defined by the ABA Standards on Corporate Monitors and IAICM's Code of Professional Conduct. The Agreement does not use the term "Monitor'; however, DOJ's press release regarding the Settlement did.

Monitor's Restrictions:

No business with Host Organization for 1 year after expiration of Term.

Documents Uploaded: McKesson-DOJ-Civil-Penalty-Settlement-Agreement-17Jan2017.pdf