Controlled Substance Due Diligence Resources
Order Monitoring Program
Suspicious order reporting FAQs for veterinarians
MWI is required to maintain an Order Monitoring Program (OMP) for identifying and investigating Customer controlled substance “orders of interest” that may be “suspicious”. MWI is further required to reject and report those orders that are ultimately deemed suspicious to DEA and State regulators per Title 21 of the Controlled Substances Act (CSA) § 832.
The CSA defines the term “suspicious order” as one that may include but is not limited to- an order for a controlled substance of unusual size, an order for a controlled substance deviating substantially from a normal pattern, and orders of controlled substances of unusual frequency. (Title 21 CSA § 802)
- The item has met one or more of the definitions of a suspicious order.
- That item has been cancelled and deleted from the order. If there were other items (controlled and/or non-controlled) on the order that were not rejected, those items will still be shipped.
- If the cancelled item is still needed, a new order must be placed for immediate patient need.
- If this was a Schedule II drug, a new DEA 222 or CSOS order must be completed for that item.
- Order for immediate patient need, avoid “stocking up” on controlled substance items.
- Limit the number of individuals allowed to place orders to avoid duplicate orders that may appear suspicious.
- Respond to email inquiries from MWI Investigators regarding questionable orders to try and resolve issues surrounding orders of interest.