One of the benefits of being a locum tenens provider is the ability to travel and practice in various health care facilities and communities around the US. Many enjoy this aspect of being a locum, and for some, it is one of their biggest motivators to transition to a locum tenens career.
For those medical providers who are starting to or thinking of working in multiple states regularly, one of the most common questions I am asked as a credentialer is, “How do locum tenens providers manage DEA registrations?”. According to the Controlled Substances Act, a practitioner is required to have a separate DEA registration for “each principal place of business or professional practice where controlled substances are manufactured, distributed, or dispensed,” see 21 U.S.C. § 822(e). Options for locum tenens providers This may not always be conducive for locum tenens providers as the process of obtaining a new DEA registration can be tedious and costly. As suggested by the DEA, there are a few options for locum tenens providers:
- Practitioners may need to obtain a separate DEA registration in each state where they plan to administer, dispense, or prescribe controlled substances. This can take up to a week to issue and another week to be mailed to the provider.
- If the practitioner will be working solely in a hospital/clinic setting, they may use the hospital’s DEA registration instead of registering independently with DEA if the hospital agrees and the situation warrants, see 21 C.F.R. § 1301.22(c).
- Practitioners may transfer their existing DEA registration from one state to another as needed by either contacting DEA’s Registration and Program Support Section at 1-800-882-9539 or request the change online at www.DEAdiversion.usdoj.gov. DEA will investigate each modification of registration as if it was a new application. DEA will issue a new DEA certificate with the appropriate changes if DEA approves the modification, see 21 C.F.R. § 1301.51. This can take 24-48 hours to update and can be printed instantly off the DEA’s website.
Exceptions There are some exceptions to the CSA’s regulation of DEA registration. These include:
- For those practitioners practicing at multiple locations within the same state. They are not required to register all the locations unless the provider maintains supplies of controlled substances at those locations, see 21 C.F.R. § 1301.12(b)(3) & 21 U.S.C. § 823(f).
- A practitioner who is an employee or contractor of the Indian Health Service, or is working for an Indian tribe or tribal organization, is regulated by the Indian Self-Determination and Education Assistance Act, see 25 U.S.C. 450 et seq. The majority of tribal healthcare facilities only require an active DEA, with the exception of Alaska, who requires and active license and DEA in the state.
- A provider can apply for a fee-exempt status DEA registration. This only applies to providers who work direct with an agency of the United States, i.e. military obligations, VAMCs. There is an extensive approval process before this type of DEA is issued and this DEA can only be used for patients of the US agency that the provider is contracted with. For those providers who wish to change their DEA to a fee-paid status, they can either fill out the following form or apply for a new DEA. For those who choose to fill out the form, this does not change the expiration of the DEA, it only updates the status.
Further Reading Here are some guides for providers with regard to their DEA registration.
- How to Apply for a New DEA Registration Number
- How to Re-Register Your DEA Number
- How to Request a Duplicate DEA Registration