DEA Reverses Announced Change to Registration Renewal Process
 
Question: What is the impact of the DEA’s reversal of its registration policy? What change is being made to the registration renewal process?
 
Answer: The Drug Enforcement Administration’s (“DEA”) change to it registration policy, which was to take effect January 1, 2017, has been reversed. Last week’s StatLaw® Q&A contained an advisory of the new policy. However, the day after the article was published, the DEA again revised its policy. As of last week, the DEA has reversed its decision and posted a notice that it is retaining its current policy and procedures, with one minor change, regarding registration renewals.

As per the DEA, starting January 2017, the DEA will no longer send its second renewal notification by mail. Instead, an electronic reminder to renew will be sent to the email address associated with the DEA registration. The DEA will otherwise retain its current policy and procedures with respect to renewal and reinstatement of registration.

The DEA policy is as follows:

·  If a renewal application is submitted in a timely manner prior to expiration, the registrant may continue operations, authorized by the registration, beyond the expiration date until final action is taken on the application.

·   DEA allows the reinstatement of an expired registration for one calendar month after the expiration date. If the registration is not renewed within that calendar month, an application for a new DEA registration will be required.

· Regardless of whether a registration is reinstated within the calendar month after expiration, federal law prohibits the handling of controlled substances or List 1 chemicals for any period of time under an expired registration.

Weekly Charting Tip:
Try very hard to get along with your fellow physicians and health care providers in the hospital setting. With mergers and acquisitions, we are defending more and more cases involving physicians being labeled as disruptive. If you disagree with a colleague or administrator, professionally state your opinion and do not dwell on it. Do not raise your voice. Do not use profanity. Do not threaten.  As a physician, you are a target with a bullseye on your back. Additionally, the hospital has legal resources far beyond what you can afford. Bite your tongue and do not become argumentative. The privileges and license you save may be your own! Until next week, Larry Kobak, Esq.

 
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