This is a big deal, FINALLY the DEA will get off our asses when we are between jobs...

[Cideous]

Got this today and why it is very important.  According to the stupid DEA agent who contacted me (in Texas), you MUST have a workplace to have an active DEA license( eg you could not use your home address), even if you are between jobs.  According to her, if I lose my job, I lose my DEA license.   When I brought up that I was between jobs, hence using my home address of record when I paid their ungodly fee, she went bat shit crazy on me.  This was 2 years ago.  It seems common sense does finally catch up to even those in the dea......

 

P.S.  Don't you just LOVE the use of "Mid-Level" to identify us by the govt?  LOL "Assistant" must go away......We are MCP's.

 

 

 

 

 

Drug Enforcement Administration Diversion Control Division Guidance Document

Title: Use of a Home Address as a Principal Place of Business or Professional Practice by Individual and Mid-level Practitioners

Summary: This guidance document addresses issues pertaining to individual and mid-level practitioners’ use of their home address as a principal place of business or professional practice and the home address becoming controlled premises subject to unannounced inspections and administrative warrants under existing Drug Enforcement Administration (DEA) regulations.

Activity: Using a Home Address as the Principal Place of Business or Professional Practice To Whom It Applies: DEA-Registered Individual and Mid-Level Practitioners

Question: Can an individual practitioner, to include a mid-level practitioner, use their home address as the principal place of business or professional practice?

Answer: Yes. An individual practitioner is a physician, dentist, veterinarian, or other individual licensed, registered, or otherwise permitted, by the United States or the jurisdiction in which he/she practices, to dispense a controlled substance in the course of professional practice, but does not include a pharmacist, a pharmacy, or an institutional practitioner. A mid-level practitioner means an individual practitioner, other than a physician, dentist, veterinarian, or podiatrist, who is licensed, registered, or otherwise permitted by the United States or the jurisdiction in which he/she practices, to dispense a controlled substance in the course of professional practice. Examples of mid-level practitioners include, but are not limited to, health care providers such as nurse practitioners, nurse midwives, nurse anesthetists, clinical nurse specialists and physician assistants who are authorized to dispense controlled substances by the State in which they practice. See 21 CFR 1300.01(b). In addition, individual and mid-level practitioners must also be in compliance with applicable State, local or tribal laws.

DEA regulations require a separate registration 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. 21 CFR 1301.12(a). DEA regulations do not prohibit individual and mid-level practitioners from using their home address.

If an individual practitioner or mid-level practitioner does choose to use their home address as a principal place of business or professional practice, the location becomes a “controlled premises” and is subject to unannounced inspections and administrative warrants under existing DEA regulations. See 21 CFR 1316.01–1316.13. An individual practitioner or mid-level practitioner whose DEA-registered location is a home must comply with the established recordkeeping requirements (see 21 CFR 1304 and 1305) and security requirements. See 21 CFR 1301.71, 1301.75 – 1301.76.

     

The contents of this document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law, regulations, or Department of Justice policies.

EO-DEA183, DEA-DC-052, November 3, 2021 (Revised #1), Original Posted July 8, 2021.

[AndreaG]

So, who would you list as your supervising physician and their license number in this case? I’m a new PA and am licensed in my state of practice, but do not have employment yet.

 

I was recommended by someone who interviewed me to submit my DEA application but how can I do this without a SP and their license number? 

[ohiovolffemtp]

I've not had to supply any information about supervision on my DEA applications: Ohio and Indiana.  I do have to supply my license number and whatever other "certification to prescribe" information the state requires.

[Cideous]

1. Texas does not require a supervising doc on your dea just a place of practice which FINALLY can be your home if you are between jobs.  Let me be very clear....a few years ago I was told by the DEA out of Dallas that if I was between jobs, I would have to surrender my DEA.  Which is asinine to say the least.  It's why this is a big deal.