Should DEA Provide Guidance & Conduct Rulemaking on Suspicious Orders to Ensure Balanced Approach to Reduce Abuse & Ensure Avail. of Needed Medicine?

The increase in prescription drug abuse in the United States is the result of multiple factors (e.g.,rogue Internet pharmacies, pain clinics, and doctor shopping) often requiring law enforcement and the regulated industry to play catch-up to address the ever-changing sources of diversion. However, the bulk of the Drug Enforcement Administration’s (DEA) enforcement efforts have been directed at placing more responsibility on the regulated industry, most notably wholesale distributors, to police its customers. While some legislation has been passed to assist both DEA and the industry to root out unlawful activity, most notably the Ryan Haight Online Pharmacy Consumer Protection Act, DEA has failed to provide sufficient guidance in areas, such as suspicious order monitoring and dispensing practices, to be effective.