Moonlighting and DEA Registration...so confused...

[GonnaBeADoc2222]

PGY3 EM resident here. Working on getting my ducks in a row to do some moonlighting during PGY4 year. Just obtained state license and just applied for federal DEA registration. I am hoping to moonlight at two separate facilities next year. Both facilities are in the same state. Do I need to obtain two separate DEA registrations for these practice locations.? The language that is used on the DEA website is very confusing and seems to suggest that this may be required. I can't imagine having to pay $730 dollars twice...but this is the government so I wouldn't be surprised. Can anyone offer clarification on this issue???

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[Daedalus]

The DEA actually answers this specifically on their site - the answer is that no, you do not need to register again if you work at multiple sites in one state (as long as you only prescribe from those sites - if you actually "dispense" controlled substances, you have to have another registration)

http://www.deadiversion.usdoj.gov/faq/locum_tenens.htm

 

[GonnaBeADoc2222]

I saw that but I was confused as to what "dispense" actually means. Is "dispense" referring to physically giving a patient meds (like a methadone clinic, etc)? Can you assume that "dispense" doesn't mean the act of writing an order or prescription for a controlled substance that an RN carries out? In which case you would not need two DEA registrations.

 

[Daedalus]

Seems pretty clear to me. If you're only prescribing and not dispensing (i.e. providing the actual controlled substance itself from that location, which does not apply to any ED doc that I know of) within the same state, you don't need a separate DEA registration. If you're not convinced, call or e-mail the office of diversion control - I've found them to be pretty helpful with questions.

"practitioners who register at one location in a state, but practice at other locations within the same state, are not required to register with DEA at any other location in that state at which they only prescribe controlled substances."
--
"The term "dispenser" means a practitioner who so delivers a controlled substance to an ultimate user or research subject."

 

[Boatswain2PA]

Seems pretty clear to me. If you're only prescribing and not dispensing (i.e. providing the actual controlled substance itself from that location, which does not apply to any ED doc that I know of) within the same state, you don't need a separate DEA registration. If you're not convinced, call or e-mail the office of diversion control - I've found them to be pretty helpful with questions.

"practitioners who register at one location in a state, but practice at other locations within the same state, are not required to register with DEA at any other location in that state at which they only prescribe controlled substances."
--
"The term "dispenser" means a practitioner who so delivers a controlled substance to an ultimate user or research subject."

Some rural places this does get confusing. Some of the places I work at don't have 24 hr pharmacies, so we sometimes dispense meds from a small ED pharmacy. For pain meds it is usually a small pre-packaged bottle with #6.

I "think" we get around the 2 DEA registration rule because I simply write the prescription, and the ED RN "fills" it from the ED pharmacy.

Maybe I should call the DEA and make sure we're doing it right....

 

[Daiphon]

PGY3 EM resident here. Working on getting my ducks in a row to do some moonlighting during PGY4 year. Just obtained state license and just applied for federal DEA registration. I am hoping to moonlight at two separate facilities next year. Both facilities are in the same state. Do I need to obtain two separate DEA registrations for these practice locations.? The language that is used on the DEA website is very confusing and seems to suggest that this may be required. I can't imagine having to pay $730 dollars twice...but this is the government so I wouldn't be surprised. Can anyone offer clarification on this issue???

Only reason you'd need 2 is if one of them is "paid for" by your program... if you work for the feds/state/county, your chair/PD can attest to this governmental employment & the fees are waived; but only insofar as your DEA is used at a governmental site.

If neither site falls into this category, you have to pay bit only need 1 DEA. Other posters are correct about the "dispensing" aspect.

Cheers!
-d

Semper Brunneis Pallium

 

[bjs317]

Just another question...does the DEA communicate with you via email during this process or does your certificate just show up in the mail? They didn't even send me an email confirmation when I submitted the application which I thought was odd...

 

[BigRedBeta]

In my experience, just shows up. I had my applications handled by locum tenens companies though.

 

[Daedalus]

but only insofar as your DEA is used at a governmental site.

Just a slight correction here - a fee exempt DEA number isn't only good at "governmental sites" - it is valid at all participating institutions in the course of your training. Your employment by a government agency (usually a state university in the case of residents) is what gets you the fee exemption, so you can use it throughout the course of that employment, but only in that context. So if you do some rotations at the private hospital down the street, it doesn't mean you all of a sudden can't use your DEA number there.

Source: there are lots that you can google, but see this UCSF policy for reference: http://www.fresno.ucsf.edu/housestaffportal/documents/gmec/DEAPolicy.pdf

 

[Daiphon]

Just a slight correction here - a fee exempt DEA number isn't only good at "governmental sites" - it is valid at all participating institutions in the course of your training. Your employment by a government agency (usually a state university in the case of residents) is what gets you the fee exemption, so you can use it throughout the course of that employment, but only in that context. So if you do some rotations at the private hospital down the street, it doesn't mean you all of a sudden can't use your DEA number there.

Source: there are lots that you can google, but see this UCSF policy for reference: http://www.fresno.ucsf.edu/housestaffportal/documents/gmec/DEAPolicy.pdf

True. That's what I meant to express, and thanks for clearing up my verbiage as pertains to the residency issue. d=)

Once attendinghood begins, if one continues employment by a fee-exempt site, and avails oneself of the fee waiver, then you can't really port the DEA to non-exempt sites (which is why I have 2 - primary academic employment & community moonlighting).

-d

Semper Brunneis Pallium

 

[shookwell]

I agree with above. I got a fee-exempt DEA during residency but paid for a regular once I was doing external moonlighting.

If your DEA looks like this, you probably need another one to moonlight (unless your moonlighting institution also qualifies for fee exempt status). You can probably get away with not getting another one but I wouldn't recommend it.