NCPA
March 31, 2021
NCPA submitted comments to the Drug Enforcement Administration in response to the reopened comment period on its proposed rule on Suspicious Orders of Controlled Substances. NCPA recommendations include: extension of the proposed deadline of seven calendar days to 10 business days for investigation and reporting of orders received under suspicious circumstances, clarification of the new recordkeeping provision related to these orders, clarification of new definitions to support the new suspicious order monitoring framework, and clarification of the applicability of DEA regulations to require dispenses that distribute pursuant to the “five percent rule” to design and operate a suspicious order monitoring system. NCPA also sent a letter with the American Society of Health System Pharmacists and the National Association of Chain Drug Stores requesting that DEA reopen the comment period for an additional 180 days to allow pharmacy stakeholders to develop more meaningful input.