6.6 Opioid Overdose Reversal & MOUD: Naloxone Prescribing, Standing Orders, Immunity & Buprenorphine

Why this matters

Oregon treats overdose prevention as core pharmacy practice. Short-acting opioid antagonist (SAOA) law moved from the old ORS 689.681 series to ORS 689.800–689.813 in 2023. The Board's prescribing rule is OAR 855-115-0350, and a separate statute authorizes pharmacist prescribing of medications for opioid use disorder (MOUD) (ORS 689.698). The MPJE tests when pharmacists may or must provide naloxone, who may receive it, liability protections, and the DEA requirement for MOUD.

Short-acting opioid antagonists

A short-acting opioid antagonist is any short-acting FDA-approved drug for the complete or partial reversal of an opioid overdose, such as naloxone nasal spray or injection, or nalmefene nasal spray (ORS 689.802(1)(c)).

When a pharmacist may prescribe (ORS 689.802; OAR 855-115-0350)

An Oregon pharmacist may prescribe an FDA-approved SAOA and the supplies needed to administer it:

1. When dispensing an opioid prescription above 50 morphine milligram equivalents (MME). The pharmacist may offer to prescribe and provide naloxone along with the opioid.
2. To an individual seeking an SAOA: a person at risk, or a family member, friend or bystander.
3. To an entity seeking an SAOA, such as a school, shelter or business.

The pharmacist documents the encounter under OAR 855-104-0055. Nasal-spray SAOA products are exempt from certain labeling requirements (ORS 689.813; OAR 855-115-0350). Separately, any person may buy OTC naloxone nasal spray (approved for nonprescription sale in 2023) without a prescription.

Standing orders and the duty to dispense (ORS 689.808)

OHA's Public Health Officer, or an OHA-employed physician, may issue a statewide or regional standing order for an SAOA and supplies for:

• People at risk of overdose.
• People or entities who may encounter someone at risk.
• Owners of public buildings.

Upon the request of an individual or entity, a pharmacist shall dispense an SAOA pursuant to the standing order. A person acting in good faith who possesses, distributes or administers under the standing order is immune from civil and criminal liability unless the conduct is wanton misconduct. They are also immune for declining to do so.

Notice and public access

• Every retail and hospital outpatient pharmacy must post conspicuous written notice that an SAOA and supplies are available (ORS 689.806; OAR 855-041-1035).
• Owners of buildings with public access may keep SAOA kits obtained under a standing order. Members of the public who administer one in good faith are immune (ORS 689.811).
• Social services agency employees, such as shelter staff, and school personnel trained under State Board of Education rules may administer an SAOA not distributed to them (ORS 689.804).

Good Samaritan protection (ORS 475.898)

A person who contacts emergency medical services or police for someone experiencing a drug-related overdose, and the person experiencing the overdose, are immune from arrest, prosecution or civil penalty for listed possession offenses when the evidence was obtained because of the call. The offenses include possession of controlled substances, of specified opioids and stimulants, of prescription drugs without a prescription, and of paraphernalia. The immunity also covers probation and release violations based on that evidence. It does not cover other crimes, such as delivery or manufacturing.

PDMP

SAOA dispensing is excluded from Oregon PDMP reporting (ORS 431A.855(4)).

Medications for opioid use disorder (ORS 689.698)

An Oregon pharmacist may prescribe, dispense and administer MOUD under:

• a statewide protocol developed by the PHPFAC with an addiction-medicine physician and adopted by the Board, or
• a CDTM agreement.

Because buprenorphine products are Schedule III, a pharmacist may register with DEA as a mid-level practitioner to prescribe Schedule II–V MOUD (ORS 689.698(2)). The Board's MOUD Initiation and Continuation/Modification protocols (v. 02/2026) require:

• Eight hours of ACPE-accredited OUD training, including MOUD prescribing, before applying for DEA registration.
• A current DEA registration for Schedule III.
• The standardized intake forms and care pathways, and a required patient instruction sheet for initiation.

A pharmacist-prescribed MOUD prescription may be transmitted electronically to a different dispensing pharmacist (ORS 475.188). Since the federal X-waiver requirement was eliminated in 2023, any DEA practitioner registration that includes Schedule III covers buprenorphine for OUD, subject to the DEA training attestation for new or renewing registrants.

Exam scenario

A patient fills oxycodone 10 mg every 6 hours (60 MME/day). The pharmacist may offer to prescribe naloxone under OAR 855-115-0350, because the prescription exceeds 50 MME, and documents the encounter. The patient's roommate later comes in alone and asks for naloxone. The pharmacist may prescribe it to the roommate, or must dispense it if the request is made under OHA's standing order. Nothing is reported to the PDMP. If the patient later asks the pharmacist to start buprenorphine, the pharmacist may do so only after the 8 hours of training, with a DEA registration covering Schedule III, and by following the MOUD initiation protocol.