DEA REGISTRATION
With the introduction of a new continuing education requirement, which I will briefly touch on in this article (for more on the requirement, see the article “FAQ about the new DEA opioid training requirement” and watch our video by clicking here), a dentists’ DEA registration has been a large topic of conversation lately. I wanted to give a quick breakdown of DEA registration and how to interact with the federal government.
The Drug Enforcement Agency (DEA) is housed under the U.S. Department of Justice (DOJ) along with other entities such as the Federal Bureau of Investigation, U.S. Marshals Service, the office of the U.S. Attorney General and many other entities. On the Department of Justice’s website, they list over 50 different agencies that are under their purview. The mission of the DEA is to enforce the controlled substances laws and regulations in the U.S., bring to the civil and criminal justice system organizations and people who are involved in illicit drug distribution and production, and to support programs aimed at reducing the availability of illicit controlled substances. Within the DEA there are also more divisions, but registration of dentists and other providers is housed under the Diversion Control Division.
Now you know way more than you ever cared to about the structure of the U.S. DOJ. However, I think it is important to understand the importance of the Department and how interactions with this government entity should be taken seriously. So, the normal interaction with the DEA that dentists have is in the form of registration to be able to prescribe controlled substances to patients. We won’t get into possible other interactions with the DEA or DOJ; if you have those I would suggest getting a good attorney.
For a new registration with the DEA, an Ohio licensed practitioner will fill out form 224 to obtain their original clearance to prescribe controlled substances. Once the registration is approved the practitioner will have active registration for three years. The current cost of this registration for a three-year period is $888. You may renew your registration up to 60 days prior to expiration of the current registration with form 224a. Also, if your registration expires you have 30 days to renew your registration before you will be required to submit a new registration instead of a renewal. At any time when a registration is expired, a dentist should not be prescribing any controlled substance as that would be in direct violation of the controlled substances laws. To avoid any confusion on renewal make sure to have your information up to date with the DEA; they will send email reminders at 60, 45, 30, 15, and 5 days prior to expiration. Further, on the topic of renewal, after June 27, 2023 when a practitioner renews a registration they will be asked to attest to 8 hours of continuing education on opioids. Please see the ODA website articles and videos explaining the new requirements and how to fulfill them.
Lastly, I wanted to discuss any specific Ohio regulation regarding registration with the DEA. Ohio does not have a separate prescribing license that is required. However, for schedule II drugs, prescriptions will need to be done through electronic prescribing, unless your office falls into an exception. The largest exception to the law that was passed last year was an amendment the ODA helped draft which allows for prescribers that write less than 50 schedule II prescriptions a year to be exempt from the electronic prescribing mandate.
If you have questions on what constitutes a controlled substance or if all dentists must have a DEA registration, please reach out to me at 614-486-2700 or eric@oda.org.
