|Matter Type:||DOJ Civil|
|Relevant Jurisdiction(s):||Washington, DC|
|Reporting Agencies:||Drug Enforcement Administration|
|Resolution Form:||Settlement Agreement|
|Agreement Date:||January 17, 2017|
|Monitor Reference Term:||Independent Review Organization|
|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:|
|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.
No business with Host Organization for 1 year after expiration of Term.