NCPA Advocacy Center Update, December 17, 2016
Pharmacists should be aware that as of January 1, 2017, DEA is implementing a new policy related to registrant renewals. DEA quietly changed the policy via a website posting informing registrants that as of January 1, 2017, those with an expired DEA registration will need to fully reapply, that is DEA will no longer allow a “grace period” for expired registrations. The policy change impacts all registrants including pharmacies and prescribers. Currently, DEA provides registrants whose license has expired a grace period to renew their license. With the new policy change DEA will only send out one renewal notification letter by mail approximately 65 days prior to the expiration date. The letter will be sent to the “mail to” address for each DEA registrant. Failure to renew prior to the expiration date will result in the original DEA registration not being reinstated. Consequently, prescriptions written and dispensed for controlled substances by registrants whose license has expired will be implicated.
DEA’s notice also clarifies that renewal applications will need to apply for new DEA registration if attempting to renew after the expiration date or if DEA has not received paper renewal applications after the expiration date. To describe this change, the notice states, “the online capability to renew DEA registration after the expiration date will no longer be available” and “If DEA has not received the paper renewal application by the day of the expiration date, mailed in renewal applications will be returned to the registrant and the registrant will have to apply for a new DEA registration.”
DEA regulations do not require pharmacists to check the DEA registration status each time a controlled substance is dispensed, however other regulations and policies may require verification that a prescription is valid such as those related to PDMPs or for reimbursement. NCPA is concerned with widespread implications of this new policy, including a decrease in patient access to controlled substances as well as audit implications for the pharmacy. We are working with other impacted registrants to share our concerns with the DEA. Here is a link to the new policy: https://www.deadiversion.usdoj.gov/drugreg/index.html
