Medical Purchasing Solutions “Know Your Customer” DEA Overview

Manufacturers and distributors of controlled substances are required by the DEA under the Controlled Substances Act to “Know Your Customer”. The Code of Federal Regulations, 21CFR Part 1301.74(b) requires distributors of controlled substances to design and operate a system to identify suspicious orders. Medical Purchasing Solutions uses a proprietary order management system to analyze controlled substance ordering practices for all customers. We are required to “Know Our Customer”, and this review is to help better know and understand your practice.

“Know Your Customer” Account Reviews

• You may have been selected because this is your first purchase of controlled substances from Medical Purchasing Solutions.
• You may have been selected if there was a deviation in your controlled substance buying pattern. This would include orders of unusual size, a change in the quantity or frequency of items that were previously purchased or attempting to purchase a controlled substance that you have not ordered from Medical Purchasing Solutions before.

“Know Your Customer” Due Diligence Questionnaire

A “Know Your Customer” Questionnaire will be sent to your practice. We understand that controlled substance purchases may be unique; as we strive to fulfill our customer’s needs, we must also maintain adequate safeguards and regulatory compliance checks on the controlled substances purchased from Medical Purchasing Solutions.

• Controlled Substance Questionnaires should be filled out in their entirety.
• Controlled Substance Questionnaire should include all controlled substances you intend to order including estimated quantities.
• If purchase quantities increase, you may be asked to submit additional information to order controlled substances.

A completed “Know Your Customer” Questionnaire submission is required. Controlled substance orders may not be placed until the questionnaire has been completed in full and reviewed by the Medical Purchasing Solutions Compliance Department.

In some cases, additional information or supporting documents may be requested such as:

• Letter of Justification
  Medical Purchasing Solutions may request a “Letter of Justification” to validate shifts in purchasing patterns of controlled substances.
• Office Photographs
  Medical Purchasing Solutions may request current digital pictures of the interior or exterior of your office.