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Some PAs Will be Required to Obtain DEA Registration Starting January 1, 2015

As the Affordable Care Act (ACA) continues to roll out, many new changes and requirements are coming down the pipe for health care practitioners. Some new requirements are more complicated and confusing than others. One new requirement directly impacts many physician assistants who prescribe controlled substances.

Starting January 1, 2015, a new drug-prescribing regulation will go into effect in order to prevent prescription drug abuse and fraud. The Center for Medicare & Medicaid Services (CMS) has adopted this regulation that will change the requirements under which PAs can prescribe.

All Medicare Part D prescribers will be required to:

–       Enroll in Medicare
–       Have a valid Drug Enforcement Agency (DEA) certification before prescribing controlled           substances (and knowledgeable on the restrictions within their state)
–       Have no fines, warnings, or restrictions with state medical licensing boards

Section II of the Practitioners Manual states that every person handling controlled substances “must be registered with DEA or be exempt by regulation from registration.” Some exemptions vary from state to state and may include PAs who work for hospitals or other institutions. Those PAs may find that they are exempt from the registration requirement because they are allowed to prescribe controlled substances using their institution’s DEA certification number.

With registration the prescriber will be granted federal authority to handle the controlled substance. Once registered, the prescribing practitioner must look to see which activities are authorized under the state law for their jurisdiction. It should be noted that some state law is stricter than federal law, so it is important to know the regulations for a specific jurisdiction once a DEA registration certificate is acquired.

To apply for registration, fill out the DEA Form 224.  It can be completed online or a hard copy can be mailed to:

Drug Enforcement Administration
Registration Unit
Central Station
P.O. Box 28083
Washington, D.C. 20038-8083

You can visit the website for the form, visit any DEA field office, or call DEA Headquarters’ Registration Section in Washington, D.C. at 1-800-882-9539.

The prescribers Medicare enrollment will be revoked by CMS if the DEA certificate is revoked or suspended. This could happen if the agency determines that the prescribing practitioner has a pattern or practice of prescribing these controlled substances in a way that is abusive or a threat to the patient, or “fall outside the form of prescribing.”

It’s so important to understand your state’s requirements and to be current in any and all necessary licensing in order to be in compliance with new rules and regulations. Talk to your employer or institution if you have questions and be familiar with the DEA requirements in your area. A good starting place for further information is to scroll through the manuals here:

Sources: 1, 2, 3

Image: Charles Williams

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