Multiple dea licenses in the same state?

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finalpsychyear

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Trying to get clarification here. I currently have a dea number but do not administer or dispense meds at my private practice thus you can have multiple locations or sites without a separate dea for each per the rules.

The telepsych place I contract at is now dispensing sublucade and is saying my dea must have this address as the default location for my dea. Am I able to do this without effecting my private office?

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You only need One DEA per state (unless you have one government and one private one). Since you don't rx controlled substances in your pp I dont see hat the issue is to change your address for your DEA. This can only be a positive. Just update the address online.
 
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You only need One DEA per state (unless you have one government and one private one). Since you don't rx controlled substances in your pp I dont see hat the issue is to change your address for your DEA. This can only be a positive. Just update the address online.

I did call the dea. They basically said you can have as many offices in the state even if you rx controls under one dea. The issues is if one of those sites your dea is being used to give sublocade for example that must be the address on file associated with your dea. If you decide for whatever reason to admin sublocade at another location then you need a separate dea since you have 2 sites that are administering medications.
 
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From my knowledge you need a DEA license for every place you are prescribinh controlled substances.

e.g. you work at a PP clinic and give rx for controlled you need a DEA license for there, you prescribe from another location (even next door) you need another license for that site.

The one that moved around or could be used in many different locations was the X waivered one for buprenorphine because you only have one X number. The X number has been deprecated so you don't need to that anymore.
 
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From my knowledge you need a DEA license for every place you are prescribinh controlled substances.

e.g. you work at a PP clinic and give rx for controlled you need a DEA license for there, you prescribe from another location (even next door) you need another license for that site.

The one that moved around or could be used in many different locations was the X waivered one for buprenorphine because you only have one X number. The X number has been deprecated so you don't need to that anymore.
this is not correct information. I just got off the phone with the dea. One dea license can prescribe in the same state at multiple locations. You run into needing a separate dea if you are administering (sublocade) or storing controls at more than 1 location.
 
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DEfining "dispense" to include "the prescribing and administering of a controlled substance"). EO-DEA191, June 23, 2020


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.

Source:

 
DEfining "dispense" to include "the prescribing and administering of a controlled substance"). EO-DEA191, June 23, 2020


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.

Source:


I already got confirmation with a dea agent directly about this. prescribing is not dispensing. See point 3 below. Again, this all has to be in the same state.

§ 1301.12 Separate registrations for separate locations.​


(a) A separate registration is required 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.
(b) The following locations shall be deemed not to be places where controlled substances are manufactured, distributed, or dispensed:

(1) A warehouse where controlled substances are stored by or on behalf of a registered person, unless such substances are distributed directly from such warehouse to registered locations other than the registered location from which the substances were delivered or to persons not required to register by virtue of subsection 302(c)(2) or subsection 1007(b)(1)(B) of the Act (21 U.S.C. 822(c)(2) or 957(b)(1)(B));
(2) An office used by agents of a registrant where sales of controlled substances are solicited, made, or supervised but which neither contains such substances (other than substances for display purposes or lawful distribution as samples only) nor serves as a distribution point for filling sales orders; and
(3) An office used by a practitioner (who is registered at another location in the same State in which he or she practices) where controlled substances are prescribed but neither administered nor otherwise dispensed as a regular part of the professional practice of the practitioner at such office, and where no supplies of controlled substances are maintained.
(4) A freight forwarding facility, as defined in § 1300.01 of this part, provided that the distributing registrant operating the facility has submitted written notice of intent to operate the facility by registered mail, return receipt requested (or other suitable means of documented delivery) and such notice has been approved. The notice shall be submitted to the Special Agent in Charge of the Administration's offices in both the area in which the facility is located and each area in which the distributing registrant maintains a registered location that will transfer controlled substances through the facility. The notice shall detail the registered locations that will utilize the facility, the location of the facility, the hours of operation, the individual(s) responsible for the controlled substances, the security and recordkeeping procedures that will be employed, and whether controlled substances returns will be processed through the facility. The notice must also detail what state licensing requirements apply to the facility and the registrant's actions to comply with any such requirements. The Special Agent in Charge of the DEA Office in the area where the freight forwarding facility will be operated will provide written notice of approval or disapproval to the person within thirty days after confirmed receipt of the notice. Registrants that are currently operating freight forwarding facilities under a memorandum of understanding with the Administration must provide notice as required by this section no later than September 18, 2000 and receive written approval from the Special Agent in Charge of the DEA Office in the area in which the freight forwarding facility is operated in order to continue operation of the facility.

[62 FR 13945, Mar. 24, 1997, as amended at 65 FR 44678, July 19, 2000; 65 FR 45829, July 25, 2000; 71 FR 69480, Dec. 1, 2006; 81 FR 97019, Dec. 30, 2016]
 
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The source I gave you defines dispensing as prescribing.

I'm no lawyer, looks like you got the answer you wanted so I'm not arguing with you.
 
So following your logic, why would you need another DEA license for another state?
Because the DEA said so. This question has come up numerous times, and each time it's been clear based on reading the law and people contacting the DEA that only one license per state is needed if all you are doing is prescribing.
 
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Because the DEA said so. This question has come up numerous times, and each time it's been clear based on reading the law and people contacting the DEA that only one license per state is needed if all you are doing is prescribing.
There is evidence of both statements being true, see my reference. I did not make this information up nor is it my opinion.

Again I'm no lawyer, but glad OP figured it out and others can review this thread for the advancement of knowledge in this regard.
 
Thank you everyone for clarification
 
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