Regulatory Alerts2026-01-01 | Bulletin 2026-2Bulletin 2026-2: Withdrawal of Bulletin DFR 2024-3
The Oregon Division of Financial Regulation issued Bulletin 2026-2 to withdraw Bulletin DFR 2024-3, which had previously suspended annual price increase reporting requirements. This action follows a Ninth Circuit Court of Appeals ruling that overturned a lower court decision and reinstated the Oregon Drug Price Transparency Program's mandatory reporting obligations. Consequently, prescription drug manufacturers subject to the program must resume filing annual price increase reports effective immediately upon the bulletin's issuance.
350 Winter St. NE, Rm 410, PO Box 14480, Salem, OR 97309 503-947-7694 dfr.oregon.gov 1 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must resume collection of mandatory price increase reports from manufacturers and Bulletin DFR 2024-3 is hereby withdrawn.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