The Distributor program focuses on the following elements: streamlining the DEA inspection process through the creation of a DEA inspection book, the development of automated computation charts, and a review of inventory procedures and audit techniques. Additionally, DAG will conduct a top to bottom review of DEA Standard Operating Procedures, record keeping, customer on-boarding/due diligence measures, suspicious order monitoring and reporting procedures, and ARCOS reporting. Retired DEA Diversion Investigators will also conduct both planned or surprise mock audits along with a security assessment by accredited security professionals.
The Pharmacy Program includes three components designed to ensure the owner or PIC is prepared for a DEA inspection and audit. The program is tailored to fit your type of pharmacy (retail, long term care/hospice, hospital, institutional, and compounding pharmacies).
Component 1 - Former DEA Agents or Diversion Investigators will provide training on DAG’s 15-point checklist, which includes an extensive review of DEA-required records, controlled substance "due diligence procedures," and a security analysis.
Component 2 - DAG’s analysts and investigators will provide the pharmacy with a comprehensive due diligence investigation and background screening regarding the pharmacy’s top 10 controlled drugs dispensed, the ratio of controlled drugs dispensed, the top 10 prescribing practitioners, the percentage of prescriptions and dosage units filled by the pharmacy, a list of invalid/missing DEA numbers, and a map charting the distance of patients from the pharmacy.
Component 3 – DAG’s team of former DEA auditors will conduct quarterly, semi-annual, or annual audit inspections to determine that the pharmacy is adhering to DEA regulations. The auditors will reconcile inventories and records for drugs received, on hand, dispensed, or otherwise disposed of. As former DEA investigators, the auditors will follow auditing procedures identical to those used currently by DEA field investigators.