On March 20, the Ohio Academy of Family Physicians joined the Ohio State Medical Association, in submitting comments about the State of Ohio Board of Pharmacy’s (SOBP) draft drug distributor rules. Rules pertain to the regulation of drug distributors reporting suspicious ordering activity.
(C) Drug Distributors listed in paragraph (B) of this rule shall design and operate a system to identify and report suspicious orders by customers for reported drugs. Drug distributors, upon discovery, shall notify the SOBP in writing of any suspicious orders of controlled substances placed by an Ohio-licensed pharmacy, prescriber, or wholesaler by providing the SOBP a copy of the information that the drug distributor provides to the DEA. Suspicious orders include, but are not limited to, orders of unusual size, orders deviating substantially from a normal pattern, and orders of unusual frequency.
Rules as currently drafted suggest that drug distributors may/should make site visits to customers in order to identify and report suspicious orders. While we agree that suspicious orders should be reported, drug distributors should not be inspecting customer businesses.
The Business Impact Analysis, along with a copy of the rules, can be accessed on the SOBP website.