Question: Once I obtain a DEA registration can I prescribe controlled substances anywhere in the United States as it is a Federal number?
Answer: No. A DEA individual practitioner registration is based on a State license to practice medicine and prescribe controlled substances. DEA relies on State licensing boards to determine whether a practitioner is qualified to dispense, prescribe, or administer controlled substances and to determine which schedules he/she may dispense, prescribe, or administer. State authority to conduct the above-referenced activities only confers rights and privileges within the issuing State. Thus, a DEA registration based on a State license cannot authorize controlled substance dispensing outside the State. See Registration Requirements for Individual Practitioners Operating in a "Locum Tenens" Capacity, 75 FR 55499, 55501 (Oct. 28, 2009); 21 U.S.C. 823(f); 21 CFR 1306.03(a). EO-DEA089, October 21, 2020
Question: Is a separate registration required for each principal place of business or professional practice?
Answer: Yes. 21 CFR 1301.12(a), "A separate location is required for each principal place of business or professional practice at one general physical location where controlled substances are manufactured, distributed, imported, exported, or dispensed by a person." EO-DEA090, October 9, 2020
Question: I currently have a DEA registration to import controlled substances into the United States. Do I need to obtain a separate DEA registration as a chemical importer to also import a scheduled listed chemical product (SLCP) as defined under the Combat Methamphetamine Epidemic Act of 2005 (CMEA) (i.e., pseudoephedrine, ephedrine, or phenylpropanolamine), or a drug product that contains a List I chemical?
Answer: No. Under specific circumstances a separate DEA registration as a chemical importer is not required if you hold a registration to import controlled substances. DEA regulations provide a waiver to the separate registration requirement for certain List I chemical activities if the person is already registered with DEA to import controlled substances. 21 CFR 1309.24. Specifically, any person who imports or exports an SLCP or other product containing a List I chemical described and included in the definition of a regulated transaction found at 21 CFR 1300.02(1)(iv) is not required to obtain a separate registration for those activities if already registered to import controlled substances. See 21 CFR 1309.24(c). EO-DEA225, October 5, 2020
Question: Does DEA require that a practitioner take special classes, or some type of continuing education, before they can apply for, or reapply for, a DEA registration?
Answer: No. DEA does not have any educational requirements, but individual states may have educational requirements in order to obtain and maintain a valid license in that state. DEA merely requires that all state licensing requirements be met in order to obtain a DEA registration in that state. 21 U.S.C. 823(f)(1) and (4). EO-DEA182, October 5, 2020
Question: I am a practitioner, but I never plan on administering, dispensing, or prescribing a controlled substance. Must I have a DEA registration?
Answer: No. DEA regulations require that "only persons actually engaged in" the "dispens[ing] . . . of any controlled substance" hold a registration. 21 CFR 1301.11(a); see 21 U.S.C. 802(10) (defining "dispense" to include "the prescribing and administering of a controlled substance"). EO-DEA191, June 23, 2020
Disclaimer: Guidance documents, like this document, are not binding and lack the force and effect of law, unless expressly authorized by statute or expressly incorporated into a contract, grant, or cooperative agreement. Consistent with Executive Order 13891 and the Office of Management and Budget implementing memoranda, the Department will not cite, use, or rely on any guidance document that is not accessible through the Department's guidance portal, or similar guidance portals for other Executive Branch departments and agencies, except to establish historical facts. To the extent any guidance document sets out voluntary standards (e.g., recommended practices), compliance with those standards is voluntary, and noncompliance will not result in enforcement action. Guidance documents may be rescinded or modified in the Department's complete discretion, consistent with applicable laws.