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Oregon Adds Suspicious Order Reporting to Wholesale Distributor Requirements

Health Law Alert Edward D. Rickert, Larry P. Cote, Shannon F. O'Boye, Laura D. Pone

Recently, the Oregon Board of Pharmacy adopted a new rule for wholesale distributors, requiring that they report suspicious orders to the Board for review. The rule goes into effect on July 1, 2017.

The adoption of the new rule followed several recent settlements by wholesale distributors around the country, who are facing severe penalties for failing to report suspicious orders of controlled substances to the Drug Enforcement Administration (DEA).

The new regulation states:

A wholesale distributor must notify the Board in writing of suspicious orders of controlled substances to be distributed in Oregon upon discovery. Suspicious orders include, but are not limited to orders of unusual size, orders deviating substantially from a normal pattern, and orders of unusual frequency. OAR 855-065-0010.

The Board is hopeful that this new regulation will lead to a better system of controlled substance reporting, and will prove an effective way for the state to monitor and minimize the effects of the ongoing opioid epidemic.

For questions, please contact Ed Rickert at (312) 715-5139/edward.rickert@quarles.com, Larry Cote at (202) 372-9524/larry.cote@quarles.com, Shannon O'Boye at (312) 715-5233/shannon.oboye@quarles.com, Laura Pone at (312) 715-5090/laura.pone@quarles.com, or your Quarles & Brady attorney.