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DEA Registration and Physician Assistants
The federal government’s Drug Enforcement Administration (DEA) enforces the controlled substance laws of the United States. Controlled substances are drugs with a high potential for abuse and range from drugs with no known therapeutic indication, such as heroin or LSD, to drugs with demonstrated therapeutic values, such as Ritalin or Codeine. Physician assistants are permitted to prescribe controlled substances in 46 states, the District of Columbia, and the territory of Guam, although the list of such drugs PAs may prescribe and the conditions under which PAs may prescribe them vary according to state law. As part of its efforts to limit illegal diversion of controlled drugs, the DEA keeps detailed records of controlled substance prescriptions. To facilitate this record keeping, the DEA requires that every health practitioner who prescribes controlled substances be registered with the agency. PAs, therefore, must register in order to prescribe controlled drugs, with certain exceptions.1
PAs’ authority to prescribe controlled substances derives from state law. Therefore, the DEA will register physician assistants only if their state allows PAs to prescribe controlled substances and only once PAs have completed all of the requirements imposed by state law. Some states require controlled substance registration with a state agency, for which PAs should apply before applying for a DEA registration. If the PA fails to obtain a state PA practice license or controlled substance registration (if applicable), or has the license revoked or rescinded, then the DEA cannot issue a registration. If an existing DEA registrant loses his or her state privileges, then the DEA must also rescind or revoke the federal controlled substance registration.2
PAs may use the same DEA registration number when practicing in different locations within the same state. However, effective January 2007, a separate DEA registration is required for each state in which the PA practices.3 In addition, the privileges associated with registration will change based on state law. If, for instance, a PA moves from a state that allows PAs to prescribe Schedule II drugs to one that does not, the PA’s DEA registration will no longer allow Schedule II prescriptions.
PAs must obtain their own DEA registration numbers and may not use the numbers of their supervising physicians.4 The DEA has a registration category for mid-level providers, recognizing the ability of PAs and other professionals to prescribe controlled drugs without a physician’s signature.
PAs can apply for DEA registration through the Office of Diversion Control’s Web site at www.deadiversion.usdoj.gov or by calling 800/882-9539. DEA registration must be renewed every three years and as of November 2006, the registration fee is $551 for the three year period.
For more information, PAs may consult the Office of Diversion Control’s Questions and Answers at www.deadiversion.usdoj.gov/drugreg/faq.htm or call AAPA’s State Government Affairs staff at 703/836-2272 ext. 3212.
2/08
Where PAs May Prescribe Controlled Substances
1. 21 CFR 1306.03. There are two exceptions to the registration requirement (see Sec. 1301.22(c) and 1301.23): PAs employed by a hospital or institution may prescribe controlled substances using the institution’s DEA registration number, if the institution assigns the PA an individual code to add to the institution’s DEA number when writing controlled substance prescriptions. PAs who are employed by and authorized to prescribe by the military, the Public Health Service, or the U.S. Bureau of Prisons are also exempt from registration.
2. Office of Diversion Control, Drug Enforcement Administration, U.S. Department of Justice. Questions & Answers. www.deadiversion.usdoj.gov/drugreg/faq.htm. 26 Oct 2006.
4. Robert Walker, DEA Office of Chief Counsel, to Ann Davis, AAPA State Government Affairs, 14 May 1997.
Last Revised: 2/26/08
