September 30, 2014

Question:

Dear Jennifer, 

I am opening a second location for my practice and was told that I have to register each location separately with the DEA. Is that correct?

Thanks, 
Dr. K
 
Answer: 

Prepared by:  Richard Zimmerman, Esq. 

Yes! If you have multiple office locations where you utilize controlled substances, even within the same state, you must register each one separately with the DEA. Under 21 C.F.R. §1301.12(a), “A separate registration 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.” Any location that fits that description must have its own, separate DEA registration.

There is a limited exception to this rule that applies to individual practitioners. A practitioner who registers with the DEA at one location within a state is not required to register at another location within the same state at which they only prescribe controlled substances. Again, anything more than prescribing substances (including storing, administering, etc.) and the location must be registered with the DEA.

Instructions for registering, both for practitioners and for places of business, can be found on the DEA website. If you have any questions regarding your registration requirements, or need help with the process of filing, please don’t hesitate to contactJennifer or Richard to discuss.
 


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