On February 13, the Oregon Department of Consumer and Business Services withdrew Bulletin DFR 2024-3, which previously suspended a requirement to file certain annual price increase reports under the Oregon Drug Price Transparency Program.
The Oregon DFR states the change is effective upon issuance of Bulletin No. DFR 2026-2 (February 13, 2026). It cites ORS 646A.689 and Pharm. Research & Manufacturers of Am. v. Stolfi, 153 F4th 795 (9th Cir 2025), and explains that the previously in-force Bulletin DFR 2024-3 followed a 2024 US District Court ruling that resulted in the program’s annual price increase reporting being indefinitely suspended.
Oregon DFR further states the Ninth Circuit issued a ruling effective October 31, 2025 overturning that decision, requiring the department to “resume collection of mandatory price increase reports from manufacturers.” The bulletin is directed to all manufacturers of prescription drugs subject to the Oregon program. For insurance industry professionals in Oregon – including insurers, brokers, MGAs, underwriters, and compliance teams – the only implication explicitly set out is Oregon DFR’s statement that it is resuming collection of mandatory manufacturer price increase reports, with Bulletin DFR 2024-3 no longer in effect.
