Company Terminates Auditor That Refuses To Overlook Compliance Violations

Wrongful Termination ExpertThis case involves a 340B auditor that did audits for pharmacies and drug dispensaries to make sure they complied with Health Resources and Services Administration (HRSA) regulations. The auditor performed an audit at the defendant hospital which showed compliance problems. He submitted his audit, but the auditor’s employer informed him that the audit would not be accepted out of the company’s fear of losing the hospital as a client. The auditor refused to amend his report and was subsequently terminated. After the auditor was terminated, his former employer allegedly made changes to the report and signed the auditor’s name to the altered document.

Question(s) For Expert Witness

  • 1. Please explain your experience working as a 340B auditor.

Expert Witness Response E-099720

I have been working as an Internal Auditor/340B Specialist at a Health Company in North Dakota. This Health Company is the largest employer in North Dakota and South Dakota with over 28,000 employees. We have over 120 340B pharmacies (Hospitals and contract pharmacies) across North Dakota, South Dakota, and Minnesota. I have been conducting 340B compliance internal audits across these States in an Enterprise role completing audits of both Hospitals and contract pharmacies. I am currently working on the Apexus Advanced 340B Operations Certificate. I have not reviewed a similar case. However, I have studied about whistleblower cases and am also a member of the Association of Certified Fraud Examiners and have learned a good amount regarding whistleblower cases through this organization. I have never been sued or arrested.

Expert Witness Response E-100812

I am a senior director of hospital and health system pharmacy services and have 35+ years of experience as a senior leader directing pharmacy departments in several large academic health systems developing. During my career, I have implemented innovative and efficient programs, initiated residency training programs, and fostered research and academic pursuits. I am the former vice president and chief of pharmacy for the largest healthcare organization in my state of residence and the second largest DSH 340B program in the country. At my current firm, I have provided 340B audit services for 130+ covered entities and reviewed over a quarter million contract pharmacy transactions.


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