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Diversion
High Probability Product Selection:
- S•E•T Enterprises conducted a survey of over 60 products for a top ten pharmaceutical manufacturer to identify products with a high probability of being diverted in the distribution and dispensing channels.
- The survey identified several high potential products resulting in a suspicious purchasing identification project.
340B Suspicious Order Identification:
- S•E•T Enterprises worked with the Drug Enforcement Administration (DEA) to search for retail pharmacies that were reselling Schedule 2 narcotics on the street.
- The results were so successful at identifying diversion, the DEA required all the largest wholesalers to submit their sales data of Schedule 2 narcotics to be monitored for suspicious purchasing activity.
- On August 2, 2024, S•E•T Enterprises launched SPI340BSM,, a new service offering that identifies specific 340B covered entities that exhibit suspicious purchasing patterns that suggest products purchased from pharmaceutical and biotechnology manufacturers may be diverted (resold or dispensed to a non-patient).
- SPI340BSM provides manufacturers with a targeted list of 340B entities whose purchasing patterns signal a greater likelihood of product diversion.
- Email SPI340B@set-enterprises.com for more information
Manufacturer 340B Entity Audits:
- S•E•T Enterprises developed and utilized 340B claim validation models to evaluate duplicate Medicaid scripts and invalid script submission data against industry standard dispute tests.
- Customized dispute parameters based on manufacturer and product specific criteria. Led the implementation of dispute systems designed to automate the S•E•T proprietary dispute models.
- Created stocking level measurement models to determine which 340B entities exhibit over stocking (signaling potential reselling) and under stocking (signaling potential after market purchasing).
Wholesaler Diversion Identification:
- S•E•T Enterprises was engaged by a top ten pharmaceutical manufacturer to uncover why chargeback discounts exceeded sales on a deeply discount product sold to doctor’s offices.
- Using enhanced DEA suspicious order monitoring algorithms and models, S•E•T discovered the product was being diverted by physician’s offices back to wholesalers to be resold.
- Further, S•E•T identified which wholesalers were purchasing the product illegally and which specific customers were purchasing the product at a discount, then reselling the product (diversion) back to wholesalers to be resold again generating additional (excessive) chargeback discounts.
Manufacturer Wholesaler Audits:
- S•E•T Enterprises conducted wholesaler audits to uncover diversionary after market purchases as well as failure to report indirect sale returns (resulting in excessive chargeback discounts).
- Participated in the initial development and usage of Electronic Data Interchange (EDI) standards for the pharmaceutical industry.
- Received an industry award for contributions made while serving as a Health Industry Distributors Association (HIDA) committee member.
- Published industry white papers and developed and delivered numerous presentations covering electronic commerce issues.