Reporting Suspicious Orders by those Approved to Distribute Controlled Substances

DEA Diversion Control Division Article

date: 12/14/2022

by: Alyssa Leiva, Controlled Substance Program Officer

How does the article apply to me as a DEA Researcher Registrant?

The article below applies to anyone with a DEA registration that has been approved to distribute controlled substances. In general Individuals with DEA registrations for research do not distribute materials unless they disclosed it to the DEA during their application submission or renewal. 

If you distribute materials without approval it is considered diversion and places your ability to have a license to handle controlled substances at risk. 

If you have been granted approval to distribute you are required to design and operate a system to identify suspicious orders and notify DEA of suspicious orders, For more information read the article below. 

If you have questions please feel free to reach out to us at the Controlled Substance Program.


Centralized database required by the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act

On October 23, 2019, DEA launched the Suspicious Orders Report System (SORS) Online, a new centralized database required by the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT Act, Pub. L. 115-271). Reporting a suspicious order to the centralized database established by DEA (SORS Online) constitutes compliance with the reporting requirement under 21 U.S.C. 832(a)(3). All registrants who distribute controlled substances (within the meaning of 21 U.S.C. 802(11)) are required to design and operate a system to identify suspicious orders and notify DEA of suspicious orders. 21 U.S.C. 832(a). This obligation applies to all registrants if they distribute controlled substances, including the following:

  • Distributor
  • Manufacturer
  • Importer
  • Pharmacy
  • Hospital/Clinic
  • Teaching Institution
  • Practitioner
  • Mid-Level Practitioner
  • Mid-Level Practitioner-Ambulance Service
  • Researcher
  • Analytical Lab
  • Narcotic Treatment Program (NTP)

The SUPPORT Act states the term “suspicious order” may include, but is not limited to: an order of a controlled substance of unusual size; an order of a controlled substance deviating substantially from a normal pattern, and; orders of controlled substances of unusual frequency. Reporting SORS to the Administrator of the DEA and the Special Agent in Charge of the Division Office of the DEA for the area in which the registrant is located or conducts business local DEA Field Office and DEA Headquarters, or to DEA’s centralized database, satisfies the requirement to report such orders to the Administrator of the DEA and the Special Agent in Charge of the Division Office of the DEA for the area in which the registrant is located or conducts business. 21 U.S.C. 832.

DEA registrants that are ARCOS Online and ARCOS EDI reporters should utilize their current ARCOS log on information to access the system. DEA registrants that are not currently ARCOS reporters may register on the website in order to report SORS to DEA’s centralized database. The registration process is as follows:

  1. Go to https://apps2.deadiversion.usdoj.gov/arcos-online and click on “SORS Registration (for Non-ARCOS Reporters)” hyperlink.
  2. After completing the initial registration, a confirmation e-mail will be sent to the e-mail address provided.
  3. Once DEA approves the registration, another e-mail will be sent with a temporary password.
  4. Go to https://apps2.deadiversion.usdoj.gov/arcos-online and type in your username and the temporary password. The system will require you to change the temporary password.
  5. Upon successfully changing the password, the account will be fully registered to report to the SORS Online system.

For more information, contact SORS@dea.gov