Public interest in the Opioid Epidemic has taken a back seat to this year’s events (COVID-19 pandemic, civil unrest, raging wildfires, elections), but new developments on suspicious order monitoring are expected to continue.

 

Recent Developments

In the last two years, many aspects of suspicious order monitoring got a boost after decades of being untouched by the DEA

First, the DEA released the ARCOS (Automation of Reports and Consolidated Orders System) Enhanced Lookup Buyer Statistic Tool (read our article on it here). The tool simply provides distributors and manufacturers to obtain the number of distributors who have sold a particular drug to a customer in the last 6 months by entering performing a manual search.

Second, the DEA released the Suspicious Order Reporting System Online database as a part of the SUPPORT for Patients and Communities Act. For the first time, suspicious orders are to be reported directly to DEA headquarters, as well as local DEA offices.

 

January 2020 GAO Report

The United States Government Accountability Office (GAO) drafted a report to congressional committees on “Actions Needed to Ensure Usefulness of Data on Suspicious Opioid Orders” earlier this year (read the GAO report here).

The sweeping report settled on two major issues:

  1. There is limited proactive and robust analysis of industry-reported data by both DEA (because they don’t use the data effectively) and industry (because they don’t receive data).
  2. There need to be more effective data governance structures to manage drug transaction data.

 

Washington Takes on Suspicious Order Monitoring

A broad regulatory requirement was certified on July 9, 2020, in Washington as part of permanent rule WAC 246-945-585. Notable among the requirements is that there is more substantive reporting of suspicious orders, a monthly zero-report in the case of no suspicious orders detected, and initial customer due diligence requirements.

 

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