Oregon Drug Price Transparency Reporting: Deadline Extended to April 15, 2026

The Oregon Department of Consumer and Business Services has announced that annual price increase reporting under the state’s Drug Price Transparency Program has resumed, with the reporting deadline extended to April 15, 2026.

Prescription drug manufacturers operating in Oregon should review their pricing data and reporting obligations to ensure compliance with the updated requirements.

What Triggers a Reporting Obligation?

The threshold is clear, and a report must be submitted for each NDC if:

• The price was $100 or more for a one-month supply or for a course of treatment lasting less than one month; and
• The drug's average price increased by 10% or more compared to the prior calendar year

"Average price" isn't simply a point-in-time list price, it's the weighted average of the drug's Wholesale Acquisition Cost (WAC) over the full calendar year, with each price weighted by the number of days it was in effect.

Manufacturers should review the program's user guide for the complete calculation methodology before submitting.

Are you a Reporting Manufacturer?

Qualifying as a "reporting manufacturer" under Oregon law requires meeting all three of the following criteria:

• Being registered with the Oregon Board of Pharmacy as a drug manufacturer
• Directly or indirectly manufacturing FDA-approved prescription drugs available for sale in Oregon as defined in ORS646A.689(1)(d)
• And setting or modifying the WAC for those drugs.

Meeting all three criteria also triggers a registration requirement with the Drug Price Transparency Program and an annual assessment to fund program operations.

Manufacturers with affiliated or related entities should pay close attention, as registration obligations can vary depending on how each entity is structured.

Who Does this Apply To?

The requirement covers a wide range of facility types, including contract manufacturers, traditional manufacturers, virtual manufacturers, own-label warehouse operators, and self-distributing or direct-distributing variants of those models.

On the product side, it applies to Active Pharmaceutical Ingredients (APIs) for prescription use as well as human OTC drugs.

The Stakes are Real, so Don't Wait

State drug price transparency programs have teeth.

Nevada once levied $17.4 million in fines on diabetes drug manufacturers for deficient or missing annual reports, with penalties running $5,000 per day for non-compliance.

Oregon's program is active and enforced, and the April 15 deadline leaves little room for delay. Now is the time to audit your portfolio for qualifying price increases, confirm your registration status, and get your submission prepared.

For official registration information, the user guide, and additional manufacturer resources, visit the Oregon Drug Price Transparency Program page at: https://dfr.oregon.gov/drugtransparency/pages/manufacturers.aspx

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