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  • #16
    Originally posted by nastle View Post

    What if they are not controlled substances?
    Then all you need are just appropriate state licenses.

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    • #17
      Originally posted by nastle View Post

      What if they are not controlled substances?
      DEA only is concerned about controlled substances. Everything else is regulated by the states.

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      • #18
        Originally posted by Timparsons952 View Post
        You can get more than one dea license (ie one for every state) or you can transfer one you already have to a new state. Each time you get one it’s another $750
        This is not true at all... very bad info. DEA federal is a single license and it's based off your license number and NPI.

        What OP needs to do is simply change address on his federal DEA and get a control substance license in that new state. You can fix that within a day or two.

        You can't have multiple DEA (besides maybe one for federal VA tax exempt type work and one for everything else). You simply need your federal DEA, control substances license for the state you write, federal DEA address in primary state in which you write Rx.

        All OP is being asked to do is change DEA federal website address to the new state and to get a controlled sub lic in new state if he doesn't have one already. That is a basic req for hospitals and insurances when you change states. I have no idea why many credentialers mistakenly call it "state DEA," but many of them do. Tale as old as time... DEA is federal, not state.
        Last edited by Max Power; 01-22-2022, 02:03 PM.

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        • #19
          Originally posted by Max Power View Post
          This is not true at all... very bad info. DEA federal is a single license and it's based off your license number and NPI.

          What OP needs to do is simply change address on his federal DEA and get a control substance license in that new state. You can fix that within a day or two.

          You can't have multiple DEA (besides maybe one for federal VA tax exempt type work and one for everything else). You simply need your federal DEA, control substances license for the state you write, federal DEA address in primary state in which you write Rx.

          All OP is being asked to do is change DEA federal website address to the new state and to get a controlled sub lic in new state if he doesn't have one already. That is a basic req for hospitals and insurances when you change states. I have no idea why many credentialers mistakenly call it "state DEA," but many of them do. Tale as old as time... DEA is federal, not state.
          Agree is federal. But still need it registered to specific state. You can transfer one to any other state. If you are going to prescribe in 2 states you need 2 separate licenses from dea and it will actually be two different numbers. I have three.

          see questions 3-5 on dea site:
          https://www.deadiversion.usdoj.gov/f...ration_faq.htm

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          • #20
            Originally posted by Timparsons952 View Post

            Agree is federal. But still need it registered to specific state. You can transfer one to any other state. If you are going to prescribe in 2 states you need 2 separate licenses from dea and it will actually be two different numbers. I have three.

            see questions 3-5 on dea site:
            https://www.deadiversion.usdoj.gov/f...ration_faq.htm
            You don't even understand the process. The OP is moving from one state to another. He is not trying to practice in both (only feeling stuck since he can't start in new due to not knowing the process).

            You are telling him to get a new DEA for the new state. I get that you may have been trying to help, but it is very bad advice. All he does is change his address. It is incorrect and illegal to make a new state DEA (if anything he'd just make a new, then must cancel the old since he no longer practices or Rx there... but that would be dumb and expensive, so you simply transfer address).

            If you work and live on the NY/NJ/PA area and have offices in all three which you regularly work and Rx at, go ahead and register three times. That probably applies to <1% of all docs. That is not this guy's situation at all... he is simply needing to change the address on the DEA.

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            • #21
              Originally posted by Max Power View Post
              You don't even understand the process. The OP is moving from one state to another. He is not trying to practice in both (only feeling stuck since he can't start in new due to not knowing the process).

              You are telling him to get a new DEA for the new state. I get that you may have been trying to help, but it is very bad advice. All he does is change his address. It is incorrect and illegal to make a new state DEA (if anything he'd just make a new, then must cancel the old since he no longer practices or Rx there... but that would be dumb and expensive, so you simply transfer address).

              If you work and live on the NY/NJ/PA area and have offices in all three which you regularly work and Rx at, go ahead and register three times. That probably applies to <1% of all docs. That is not this guy's situation at all... he is simply needing to change the address on the DEA.
              this is dumb but I am stuck at hospital and bored: op said he was trying to prescribe in Illinois for awhile while also in transition to CA and wanted to know if he could do both for a bit. Agree easiest is to just trasnfer to CA but then couldn't prescribe still in IL, which was his original question...

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              • #22
                Originally posted by Max Power View Post
                You don't even understand the process. The OP is moving from one state to another. He is not trying to practice in both (only feeling stuck since he can't start in new due to not knowing the process).

                You are telling him to get a new DEA for the new state. I get that you may have been trying to help, but it is very bad advice. All he does is change his address. It is incorrect and illegal to make a new state DEA (if anything he'd just make a new, then must cancel the old since he no longer practices or Rx there... but that would be dumb and expensive, so you simply transfer address).

                If you work and live on the NY/NJ/PA area and have offices in all three which you regularly work and Rx at, go ahead and register three times. That probably applies to <1% of all docs. That is not this guy's situation at all... he is simply needing to change the address on the DEA.
                also lots of people do locums in multiple states myself included hence multiple DEA

                Comment


                • #23
                  Originally posted by Max Power View Post
                  This is not true at all... very bad info. DEA federal is a single license and it's based off your license number and NPI. What OP needs to do is simply change address on his federal DEA and get a control substance license in that new state. You can fix that within a day or two.

                  You can't have multiple DEA (besides maybe one for federal VA tax exempt type work and one for everything else). You simply need your federal DEA, control substances license for the state you write, federal DEA address in primary state in which you write Rx.

                  All OP is being asked to do is change DEA federal website address to the new state and to get a controlled sub lic in new state if he doesn't have one already. That is a basic req for hospitals and insurances when you change states. I have no idea why many credentialers mistakenly call it "state DEA," but many of them do. Tale as old as time... DEA is federal, not state.
                  If all he is doing is moving and won't be working in the other state, then yes, you are correct: updating the address is all that is needed.

                  However, you are wrong about not being able to have multiple DEA's. I have 3 (2 for EMS) and was explicitly told by a DEA special agent that I needed a DEA for each EMS agency (even if in the same state) and was also explicitly told by him that I needed another one to practice in another state when I was thinking of picking up PRN work.
                  Question: I live on the border between two states and I have a practice in each state. Do I need to hold a separate DEA registration number in each state?
                  Answer: Yes. Since DEA's authority to register practitioners to dispense (including to prescribe) controlled substances is contingent, in part, upon the applicant's authorization in the state in which he or she practices, his or her controlled substance privileges and limits are determined by that specific state. The Controlled Substances Act requires a separate registration at each principal place of business or professional practice where the controlled substances are distributed or dispensed. See 21 U.S.C. 822(e)(1), 21 CFR 1301.12(a). Therefore, a practitioner who maintains a professional practice location in multiple states has established, for registration purposes, a principal place of business in each of those states. Consequently, DEA requires that the practitioner obtain a separate DEA registration in each state. Further, to do so the practitioner must first obtain authorization to handle controlled substances in each state where he or she has an office. For additional information please see the Final Rule titled: Clarification of Registration Requirements for Individual Practitioners, which DEA published in the Federal Register on December 1, 2006. EO-DEA181, November 2, 2020

                  Comment


                  • #24
                    Originally posted by southerndoc View Post

                    If all he is doing is moving and won't be working in the other state, then yes, you are correct: updating the address is all that is needed.

                    However, you are wrong about not being able to have multiple DEA's. I have 3 (2 for EMS) and was explicitly told by a DEA special agent that I needed a DEA for each EMS agency (even if in the same state) and was also explicitly told by him that I needed another one to practice in another state when I was thinking of picking up PRN work.
                    Question: I live on the border between two states and I have a practice in each state. Do I need to hold a separate DEA registration number in each state?
                    Answer: Yes. Since DEA's authority to register practitioners to dispense (including to prescribe) controlled substances is contingent, in part, upon the applicant's authorization in the state in which he or she practices, his or her controlled substance privileges and limits are determined by that specific state. The Controlled Substances Act requires a separate registration at each principal place of business or professional practice where the controlled substances are distributed or dispensed. See 21 U.S.C. 822(e)(1), 21 CFR 1301.12(a). Therefore, a practitioner who maintains a professional practice location in multiple states has established, for registration purposes, a principal place of business in each of those states. Consequently, DEA requires that the practitioner obtain a separate DEA registration in each state. Further, to do so the practitioner must first obtain authorization to handle controlled substances in each state where he or she has an office. For additional information please see the Final Rule titled: Clarification of Registration Requirements for Individual Practitioners, which DEA published in the Federal Register on December 1, 2006. EO-DEA181, November 2, 2020

                    Kudos. Your situation is different from the OP... your situation is complicated and dissimilar to his own. He does not reside and work in multiple states or do a weird blend of public/govt work. He is therefore not allowed to have multiple DEA (nor should he want to waste that money). I think it is confusing and incorrect to recommend he try for multiple (which you did not). That takes much longer, costs more, and he would have to cancel his original very soon anyways.

                    You are being myopic if you think his solution (multiple DEA for a very unique situation) is the same as your own...
                    If I live in the mountains, it doesn't mean somebody in south Florida or Dallas flat lands or also needs 4x4 for safety as I might.
                    Again, <1% of all MDs are eligible for multiple DEAs, and even fewer actually need to hold them. The vast majority have one, change if they change states. That is clearly the OP situation if you read his posting. He is stuck in the new state as he has yet to change his address.

                    Comment


                    • #25
                      Originally posted by Max Power View Post
                      Kudos. Your situation is different from the OP... your situation is complicated and dissimilar to his own. He does not reside and work in multiple states or do a weird blend of public/govt work. He is therefore not allowed to have multiple DEA (nor should he want to waste that money). I think it is confusing and incorrect to recommend he try for multiple (which you did not). That takes much longer, costs more, and he would have to cancel his original very soon anyways.

                      You are being myopic if you think his solution (multiple DEA for a very unique situation) is the same as your own...
                      If I live in the mountains, it doesn't mean somebody in south Florida or Dallas flat lands or also needs 4x4 for safety as I might.
                      Again, <1% of all MDs are eligible for multiple DEAs, and even fewer actually need to hold them. The vast majority have one, change if they change states. That is clearly the OP situation if you read his posting. He is stuck in the new state as he has yet to change his address.
                      What I'm saying is quite clear: if he practices in two states, then he is required to have a DEA registration for each state (2). If he plans to move and not practice in his original state, then he simply updates the address with the new state.

                      He does not need to list his practice address and may list his home if he so chooses. However, if he does that, his home is subject to surprise inspection by the DEA if it so chooses (rare, but I have seen it once).

                      To the OP's thoughts of telemedicine, I would highly discourage anyone from prescribing a controlled substance via telemedicine. A DEA registration is not required to practice telemedicine or prescribe non-controlled substances in any state.

                      Comment


                      • #26
                        Originally posted by southerndoc View Post

                        What I'm saying is quite clear: if he practices in two states, then he is required to have a DEA registration for each state (2). If he plans to move and not practice in his original state, then he simply updates the address with the new state.

                        He does not need to list his practice address and may list his home if he so chooses. However, if he does that, his home is subject to surprise inspection by the DEA if it so chooses (rare, but I have seen it once).

                        To the OP's thoughts of telemedicine, I would highly discourage anyone from prescribing a controlled substance via telemedicine. A DEA registration is not required to practice telemedicine or prescribe non-controlled substances in any state.
                        So I’m doing this
                        in my old practice I’m still prescribing controlled substances ( not via telemed)
                        in new practice not prescribing any controlled substances until I’m done with my old position within the next month
                        this way I’m prescribing controlled substances only in one state
                        hope that’s kosher

                        Comment


                        • #27
                          Are people saying you can only prescribe non controlled substances in the state you are licensed in? I definitely have sent prescriptions to patients in various states I was not licensed in because they forgot meds on vacation. Or they lived in neighboring states but saw me in my office and I sent their rx to their local pharmacy. Never been an issue . . .

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                          • #28
                            Originally posted by wideopenspaces View Post
                            Are people saying you can only prescribe non controlled substances in the state you are licensed in? I definitely have sent prescriptions to patients in various states I was not licensed in because they forgot meds on vacation. Or they lived in neighboring states but saw me in my office and I sent their rx to their local pharmacy. Never been an issue . . .
                            I have heard the same thing from colleagues, but I also got away with this before I was told this is verboten.

                            still it would be nice to see a link or some source that clears this up.


                            It doesn’t really make sense. If you write a prescription, you can’t control where a patient takes it. Is it my fault if they choose to fill it across state lines? The pharmacy is only going to see my NPI anyway.

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                            • #29
                              I'm licensed in two of the 25 states that require CDS and DEA. Exhausting and expensive.
                              Practitioner's State License Requirements (usdoj.gov)

                              Comment


                              • #30
                                Originally posted by Lithium View Post
                                I have heard the same thing from colleagues, but I also got away with this before I was told this is verboten.

                                still it would be nice to see a link or some source that clears this up.


                                It doesn’t really make sense. If you write a prescription, you can’t control where a patient takes it. Is it my fault if they choose to fill it across state lines? The pharmacy is only going to see my NPI anyway.
                                I only have my Dea memorized so I give that to pharmacies in other states and it's not been an issue. This is so weird and the first I've ever heard about it being an issue. I'm at the VA now so I guess my dea is valid everywhere but I did this prior to joining the VA as well.

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