DEA Announces New Procedure for Renewal of Registrations

 
Question: What is the DEA’s new procedure for renewal of registrations? What can I do to make sure my DEA registration renewal goes smoothly?

Answer: The DEA recently issued a notice on its website that starting January 1, 2017, the DEA will only send one renewal notification for registrants to renew their registrations. The renewal notification will be sent to the “mail” address for each DEA registrant approximately 65 days prior to the expiration date. No other reminders to renew the DEA registration will be mailed. The DEA notice also states that online capability to renew a DEA registration after the expiration date will no longer be available. The registrant will be required to complete an application for a new DEA registration if the registration is not renewed by midnight eastern time of the expiration date. Paper renewal applications will not be accepted the day after the expiration date.  If the DEA has not received the paper renewal application by the day of the expiration date, mailed in renewal applications will be returned and the registrant will have to apply for a new DEA registration (www.deadiversion.usdoj.gov/drugreg/index.html). The DEA has previously followed an informal grace period and that as long as the registration was in the renewal process, pharmacies could treat the registration as valid. The AMA has forwarded a letter to the DEA voicing its concerns that the new DEA policy will cause hardship to physicians and patients. The new process will create new administrative burdens on physicians since they will need to submit entirely new registration applications and then wait for the DEA to review the application and issue a new registration number. This in turn can result in patients not being able to receive the medications they need. Physicians are urged to make sure the DEA has their most current mailing address on file and be vigilant for the DEA registration mailing well in advance of their DEA registration’s deadline and to submit renewal applications as soon as notices are received in order to avoid the matter “falling through the cracks.”

Weekly Charting Tip:

On Tuesday, the Department filed a proposed regulatory amendment to add chronic pain as a qualifying condition. It defines chronic pain as "any severe debilitating pain that the practitioner determines degrades health and functional capability; where the patient has contraindications, has experienced intolerable side effects, or has experienced failure of one or more previously tried therapeutic options; and where there is documented medical evidence of such pain having lasted three months or more beyond onset, or the practitioner reasonably anticipates such pain to last three months or more beyond onset."

The amendment will be published in the New York State Register on December 21, 2016. It will then be subject to a 45-day comment period before it can be adopted.
- Larry Kobak, DPM, JD


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