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Suspicious Order Reporting

8 published works

  1. DEA Chronicles

    Congress Seeks to Provide Clarity on Suspicious Order Monitoring

    By Larry P. Cote

    There is legislation making the rounds on Capitol Hill that seeks to provide clarity regarding the process for reviewing orders for controlled substances to determine if an order is a…

  2. DEA Chronicles

    DEA Issues New/Old Guidance on Suspicious Order Monitoring

    By Larry P. Cote

    On January 20, 2023, the Drug Enforcement Administration (DEA’s) issued a Guidance Document reiterating DEA’s long-held position regarding the detection and reporting of suspicious orders. Specifically, DEA "clarified" that “neither the…

  3. DEA Chronicles

    What to Expect from DEA in 2020 – One Guy’s Opinion

    By Larry P. Cote

    Note: The following is my best guess for what to expect in the coming year regarding controlled substance compliance obligations.  I have relied on publicly available information, my experience and…

  4. Pharmacy & Healthcare Legal Blog

    Tips from recent DEA audits and Importance of suspicious order monitoring

    By Natalia Mazina

    While the opioid epidemic continues, every provider in the drug supply chain has a duty to identify and report suspicious orders. Retail pharmacies in particular have been hit with a…

  5. DEA Chronicles

    Be Careful What You Wish For:  DEA to Update Suspicious Order Reporting Regulations

    By Larry P. Cote

    In a recently issued Request for Proposal (RFP) for Information Technology (IT) and other services in support of the Diversion Control Division, DEA indicated that it will be creating a…

  6. DEA Chronicles

    West Virginia Imposes New Suspicious Order Reporting Requirements

    By Larry P. Cote, Shannon O'Boye, Elizabeth Conti

    The West Virginia Board of Pharmacy ("Board") rolled out a new mandatory suspicious order reporting form for wholesalers at its board meeting last month.  The one-page form is designed to…

  7. DEA Chronicles

    Oregon Adds Suspicious Order Reporting to Wholesale Distributor Requirements

    By Ed Rickert, Larry P. Cote, Shannon O'Boye, Laura 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…

  8. DEA Chronicles

    Suspicious Order Monitoring

    By Larry P. Cote

    ...to infinity and beyond! For years manufacturers and distributors have searched for the holy grail of DEA compliance - specific guidance from DEA on what actually constitutes a suspicious order. …