On Nov. 2, 2020, the Drug Enforcement Administration (DEA) published notice of a new Proposed Rule, "Suspicious Orders of Controlled Substances," to "clarify the procedures a registrant must follow for orders received under suspicious circumstances." 85 Fed. Reg. 69282, 69284 ("Proposed Rule").

DEA's purported "clarification" of those obligations, however, includes an entirely new framework that not only is inconsistent with prior DEA guidance as to registrants' suspicious order reporting obligations, but more fundamentally represents a lost opportunity to achieve meaningful change. It remains to be seen whether the extended public comment period for the Proposed Rule will be further extended, however, a more comprehensive solution, one that unites disparate stakeholders and data sets in a committed public-private partnership, is necessary to stem the ongoing opioid epidemic.