Oregon Drug Price Increase Reporting Guidance Withdrawn
Summary
The Oregon Department of Consumer and Business Services has withdrawn guidance related to drug price increase reports. This action reinstates the requirement for prescription drug manufacturers to file annual price increase reports, following a court ruling that overturned a previous suspension.
What changed
The Oregon Division of Financial Regulation has issued Bulletin DFR 2026-2 to withdraw Bulletin DFR 2024-3, which had suspended the requirement for prescription drug manufacturers to file annual price increase reports. This withdrawal is a direct result of a Ninth Circuit Court of Appeals ruling on October 31, 2025, which overturned a lower court decision that had indefinitely suspended the reporting requirement under the Oregon Drug Price Transparency Program.
Prescription drug manufacturers subject to the Oregon Drug Price Transparency Program must now resume filing mandatory annual price increase reports. The withdrawal of Bulletin DFR 2024-3 is effective immediately upon issuance. Compliance officers for affected manufacturers should ensure their reporting processes are reactivated to meet these reinstated obligations.
What to do next
- Resume filing annual drug price increase reports as required by the Oregon Drug Price Transparency Program.
Source document (simplified)
350 Winter St. NE, Rm 410, PO Box 14480, Salem, OR 97309 503-947-7694 dfr.oregon.gov Oregon Department of Consumer and Business Services Division of Financial Regulation, Bulletin No. DFR 2026-2 To: All manufacturers of prescription drugs subject to Oregon Drug Price Transparency Program Date: February 13, 2026 RE: Withdrawal of Bulletin DFR 2024-3 I. Purpose: This bulletin withdraws Bulletin DFR 2024-3 re: Suspension of requirement to file certain annual price increase reports. II. Authority: ORS 646A.689 Pharm. Research & Manufacturers of Am. v. Stolfi, 153 F4th 795 (9th Cir 2025) III. Guidance: Bulletin DFR 2024-3 provided guidance to prescription drug manufacturers subject to the Oregon Drug Price Transparency Program regarding a 2024 U.S. District Court ruling that resulted in the indefinite suspension of the program’s annual price increase reporting. Subsequently, the Ninth Circuit Court of Appeals issued a ruling effective October 31, 2025 overturning that decision. Accordingly, the department must resume collection of mandatory price increase reports from manufacturers and Bulletin DFR 2024-3 is hereby withdrawn. This bulletin is effective upon issuance. ______________________________________ __________________________ TK Keen, Administrator Date Insurance Commissioner Division of Financial Regulation 2/13/2026
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