Internal Control Program

OVERVIEW
questra med communications has an established Internal Control Program that reflects its longstanding commitment to observance of the laws and regulations that govern pharmaceutical marketing and promotional activities. The goal of questra med’s Internal Control Program is to maintain a culture that promotes the prevention, recognition and resolution of potential violations of healthcare laws, rules and regulations that correspond with interactions with our clients and healthcare providers. The Internal Control Program is a key component supporting our commitment to high standards of conduct.

questra med has the appropriate resources in place to support our commitment to internal controls. We have implemented policies in order to maintain this commitment. Our Control Officer is in place to address any situations that may arise, and to provide staff with appropriate guidance and oversight on established policies and procedures. Under our Control Officer, management, staff and the healthcare professionals and clients with whom we work are provided a supportive structure. questra med conducts an Annual Internal Control Training and Certification as a requirement of employment with the company, has established written policies and procedures that are distributed to all questra med staff, and identifies action steps for instances where observance of regulations that govern pharmaceutical marketing and promotional activities are not followed.


INTERNAL CONTROL STATEMENT

questra med communications’ Internal Control Program has been established to observe federal and state healthcare laws, rules and regulations, as well as pharmaceutical industry guidelines. Our Internal Control Program abides by and reinforces the guidelines and recommendations of the Pharmaceutical Research and Manufacturers of America (PhRMA), the Office of Inspector General (OIG), and the American Medical Association (AMA), in order to maintain the same industry standards and principles as the clients we serve.


WRITTEN POLICY & CERTIFICATION

questra med is committed to ethical and legal conduct that is in observance of all relevant laws and regulations and to correcting wrongdoing wherever it may occur in the organization. Each member of our staff has an individual responsibility to report any activity by any staff, client, subcontractor, vendor or healthcare professional that appears to violate applicable laws, rules, regulations, or policies. Reporting should be done with reassurance that issues will be kept as confidential as possible.

questra med’s Internal Control Officer is charged with the responsibility of day-to-day direction, development, implementation and monitoring of the Internal Control Program.

questra med monitors internal controls through program audits, on a per project basis. Prior to program initiation, periodically during the course of a program, and upon completion of every program developed by questra med, an analysis is conducted to identify any non-observance issues, and to outline reasonable steps to correct the area of concern, including any necessary modifications to questra med’s Internal Control Program to prevent and detect violations in order to prevent recurrences. It is also mandatory that the Internal Control Officer receive regular updates of each project to ensure adherence to established policies and procedures.

On an annual basis, questra med conducts a review with staff to ensure an understanding of industry standard guidelines as set forth by the OIG, PhRMA, and AMA. Participation and demonstrated understanding of these guidelines is assessed through group discussion and case studies. Case studies may or may not include actual instances with questra med-run programs that necessitated internal control decisions. Successful completion of the annual review allows questra med’s Internal Control Officer to issue certification to appropriate staff, indicating that he/she is knowledgeable about policies and procedures in place to foster observance of our internal controls. In addition, all staff will be notified of updated guidelines as they are published, then reviewed again at the time of the annual meeting.


INTERNAL CONTROL OFFICER

Don Overcash, RPh, MBA is questra med’s President and Control Officer, responsible for overseeing and managing internal control issues within the company.

Contact questra med’s Internal Control Program with any questions regarding control issues, or to receive a copy of our Non-Observance Self Reporting document.