Responsive, knowledgeable and easy-to-work-with healthcare regulatory counsel

Susan Brichler Trujillo works with clients across the pharmaceutical drug and device distribution chain, helping manufacturers, distributors, pharmacies and healthcare providers operate successfully within their highly regulated industry. With clients including retail pharmacies, pharmacy wholesalers, durable medical equipment (DME) providers, pharmaceutical distributors, pharmacy benefit managers, hospitals, behavioral health providers, residential care providers and licensed professionals, Susan advises on:

• Regulatory compliance, including licensure and permitting
• Administrative law matters

Maintaining open lines of communication and good relationships with regulators throughout the United States, and always cognizant of a client's risk tolerance and business goals, Susan delivers solutions for her clients that minimize risk and make the most of market opportunities.

Bar Admissions

• Arizona

Education

• The University of Arizona (B.A., 1995)

• The University of Arizona (1998)

• University of Notre Dame Law School (J.D., 2004)
  • Hon. Roslyn O. Silver, U.S. District Court, District of Arizona, judicial intern (2001)

• "Alabama Battle Over Alprazolam is Done. For Now."
• "Alabama Continues Efforts to Make Alprazolam a Schedule II Drug"
• "DEA Finalizes Rule to Schedule Tramadol"
• "FDA Current Landscape - Priorities and Policies for Drug Compounding"
• "Hot Topics in Pharmacy Law"
• "Industry/Business of Pharmacy"
• "Legislative Sweeps: An Update on Recent Cases"
• "New and Improved? - A Discussion of New and Proposed State Regulations"
• "Pharmacy Case Law Update"
• "Pharmacy Compliance and Case Law Review"
• "Pharmacy Law Practices Within Health Systems"
• "State Law Updates"
• "Wyeth v. Levine, 555 U.S.____, No. 06-1249, Warning! Excluding Known Hazards from FDA-Approval Labeling Contraindicated"
• 503B Loses Federal Preemption Argument, Appeals to Ninth Circuit
• Alabama Battle Over Alprazolam is Done. For Now.
• Alabama Closer to Making Alprazolam a Schedule II Drug
• Alabama Designates Gabapentin as a Schedule V Drug
• Applications Now Available for Alaska's New Licensing Categories and Prescription Standards
• Are You Interested in the FDA's Guidance on Outsourcing Facilities? Your Time to Comment Is Ending Soon!
• Are You Ready for Alabama's New Designated Representative Requirements?
• Are You Ready for Massachusetts Non-Resident Pharmacy Licensure?
• Back to Square One: Mississippi Board of Pharmacy Reaffirms Ban on Shared Pharmacy Services
• Board's Economic Impact Analysis Disputes Industry Submissions, Board Advances Proposed Rule Without Changes
• California Board of Pharmacy Considers New Legislation Regarding Pharmacy Workplace Conditions
• California Board Proposes Central Fill Amendments That Clarify (but Limit) Shared Service Models in the State
• California Enacts Sweeping Pharmacy Bill Extending Board Sunset and Requiring Nonresident PIC Licensure
• Chicago Commissioner of Public Health Publishes Proposed Pharmaceutical Representative Licensing Rules
• DEA Issues New Regulation Formalizing Black Bag Exception for Veterinarians
• Drug Supply Chain Security Act Compliance Extended But Trading Partners Should Still Prepare Now
• FDA Announces Draft Guidance on Outsourcing Facility Sales
• FDA Announces Guidance for DSCSA Process to Request a Waiver, Exception, or Exemption
• FDA Issues Broad Exemptions from DSCSA Enhanced Drug Distribution Security Requirements
• FDA May Require Opioids to be Dispensed with Mail-Back Envelopes and Related Patient Education
• FDA Releases Declaratory Order Regarding Tirzepatide Shortage
• FDA Releases Draft Interim Guidance on Bulk Drug Substances in Compounding Under Sections 503A and 503B of FDCA
• FDA Releases Flurry of Compounding-Related Documents
• FDA Releases Guidance on Identification of Suspect Product and Notification
• Federal Court Deals Blow to FDA's Compounding MOU
• Final Definitions and Considerations for Trading Partners to Prepare for DSCSA Implementation
• Florida Board of Pharmacy Proposes Amendments to Rule on Technician to Pharmacist Ratio
• Health Care Providers Beware: Congress Expands The False Claims Act
• High Court Rules "State of Mind" Relevant in Prosecuting Prescribers under the Controlled Substance Act
• HIPAA Has Some New Teeth: Update on Interim Final Rule On "Improved Enforcement" Under HITECH
• Hot Off the Press: Mississippi Board of Pharmacy Files Proposed Rule on Shared Pharmacy Services
• Indiana Senate Bill 140 Signed into Law Imposing Reforms on Pharmacy Benefit Managers
• Missouri's New Year Resolution: New Prescription Delivery Requirements for Mail Order Pharmacies
• More Guidance Released from FDA for Drug Supply Chain Security Act Compliance
• Nevada Legislature Rejects Board of Pharmacy's Licensing Requirement for Out-of-State Pharmacists
• New Alabama Law Imposes Designated Representative Registration Requirements for Wholesalers and Manufacturers
• New California Law Affects Pharmacy Operations, Staffing Ratios, And Much More
• New FDA Draft Compounding Guidance for Pharmacies, Hospitals, and Outsourcing Facilities
• New Wisconsin Patient Consultation Rule Affecting Resident and Non-Resident Pharmacies to Take Effect on January 1, 2021
• New York Passes Much-Anticipated Law Authorizing Pharmacy Shared Services Arrangements
• New York Publishes Proposed Rule Regarding Pharmacy Shared Services Arrangements
• OIG Gives a Thumbs Down to Specialty Pharmacy Prescription Transfer Program
• Oklahoma Board of Pharmacy Proposes Temperature Control Rule for Shipping Drugs
• Oklahoma Patient's Right to Pharmacy Choice Act Preempted by ERISA
• Oklahoma Will Require Nonresident Pharmacy to Have an Oklahoma-Licensed Pharmacist-in-Charge
• Part D Pharmacies Required to Enroll in Data Exchange Module to Help Drug Price Negotiation Cash Flow Issue
• Puerto Rico Implements Licensure Requirement for Non-Resident Wholesalers & Manufacturers
• Puerto Rico Repeals Special Authorization Requirement for Nonresident Manufacturers and Distributors
• Results of Economic Impact Discussion: The Latest on Proposed Changes to Wisconsin Patient Counseling Rule That Will Impact Mail Order Pharmacies
• State Legislative Trends Restricting PBM Ownership of Pharmacies
• Susan Brichler Trujillo and Eric Johnson Write InBusiness Phoenix Article About How COVID Continues to Affect Businesses
• The Clock is Ticking: Comments to Proposed Federal Rules For Wholesalers and 3PLs are Due June 6th and Here's What We Think
• The FDA Announces Delays in DSCSA Compliance Requirements and Issues Final Version of Compounding Drug Memorandum of Understanding
• The Latest on Proposed Changes to Wisconsin Patient Counseling Rule That Will Impact Mail Order Pharmacies
• The Latest on Proposed Changes to Wisconsin Patient Counseling Rule That Will Impact Mail Order Pharmacies: Board Submits Final Rule Draft
• The Latest on Proposed Changes to Wisconsin Patient Counseling Rule That Will Impact Mail Order Pharmacies: Potential Relief for Mail Order Pharmacies?
• Update on Status of Proposed Wisconsin Patient Counseling Rule that Will Impact Mail Order Pharmacies
• US District Court for District of Arizona Holds That Amount Accepted as Payment in Full is Reasonable Expenses Incurred for Necessary Medical Services
• Utah Authorizes AI-Based Prescription Renewals
• Washington Eliminates Technician to Pharmacist Ratio
• Will Alabama Make Alprazolam a Schedule II Drug?
• "It's Okay, These Products Aren't Paid for by Medicare" - Think Again

Seminar

• 2019 Pharmacy Law Symposium
• 2021 Pharmacy Law Symposium
• 2022 Pharmacy Law Symposium
• 2023 Pharmacy Law Symposium
• 2024 Pharmacy Law Symposium
• 2025 Pharmacy Law Symposium
• 2026 Pharmacy Law Symposium
• A Titan of an Annual Case Law Update
• Case Law Review
• Case Law Update
• Quarles' 17th Annual Specialized CLE for In‑House Counsel
• Untangling State and Federal Actions Regulating PBMs