Decoding the Controlled Substance License Registration
The Controlled Substances Act mandates that every person who is prescribing, administering, dispensing or otherwise handling controlled substances has to first register with the DEA in the state or jurisdiction where they are based. This law extends to veterinarians who also need a veterinary DEA license. Havinga state medical license or controlled substance permit is a prerequisite here.
New applicants for controlled substance license registration have to submit the DEA Form 224 which is available online on the U.S. Department of Justice website, https://www.deadiversion.usdoj.gov/. A physical form can be requested from the DEA Registration Field Office which will be mailed within 10 working days.
The form contains six sections related to the background, business activity, prescribing schedules and state license of the applicant. This has to be filled and submitted along with valid documents and the application fee, which is non-refundable.
The DEA will usually take 4 to 6 weeks to process the application. Once approved, the federal agency will issue a DEA controlled substance license with a unique DEA number. This has to be mandatorily quoted on all prescriptions, bills and other paperwork related to the controlled substances. Moreover, a separate registration is required for every location where the DEA registrant will store, prescribe or administer the controlled substances.
DEA controlled substance licenses are valid for three years and must be renewed not more than 60 days before the expiry date of the registration. Any lapses thereof can beget legal action. Renewal can be done online through the DEA Form 224a which can take up to four weeks.
The Potential Roadblocks
Not every person who applies for a controlled substance license registration or DEA license veterinary is sure to get it. The DEA has the right to deny the registration/renewal for various reasons like false information on the application, suspension, revocation or denial of a state license, previous conviction/felony related to controlled substances, failure to maintain effective controls against drug diversion, etc.
In such cases, the agency will first issue a formal ‘Show Cause’ order to the applicant containing a statement of the legal basis for the hearing, the reason(s) for denial and a summary of the matters of fact and law asserted. The applicant can file a request for a DEA administrative hearing to clarify why the application should be approved instead. This will be presided by an Administrative Law Judge (ALJ) who will review the arguments of both parties before issuing a recommendation as to whether the DEA controlled substance license registration should be granted or not.
As professional DEA compliance experts, we can guide and oversee the process of applying for DEA license veterinary or regular license application/renewal from start to finish. Being intimately familiar with the DEA norms and requirements, we will ensure that everything is in order and afford you full chances of getting the DEA controlled substance license. We can also provide the necessary assistance on the off chance that the application is found wanting for some reason.