Training Requirements Standards

Upon initial application, or the first renewal of a physicians’ DEA registration (beginning on June 27, 2023), physicians will be required to check a box on their online DEA registration form – regardless of whether a registrant is completing their initial registration application or renewing their registration - to attest to having met one of the three requirements for training compliance.

1.      Board certification in addiction medicine or addiction psychiatry from the American Board of Medical Specialties, the American Board of Addiction Medicine, or the American Osteopathic Association

2.      Graduated in good standing from an accredited U.S. (allopathic or osteopathic) medical school, dental school, physician assistant program, or advanced practice nursing school within the past five years of June 27, 2023, and successfully completed a comprehensive curriculum that included no less than eight hours of training on:

·       Treating and managing patients with opioid or other substance use disorders, including the appropriate clinical use of all drugs approved by the Food and Drug Administration for the treatment of a substance use disorder; or

·       Safe pharmacological management of dental pain and screening, brief intervention, and referral for appropriate treatment of patients with or at risk of developing opioid and other substance use disorders.

3.      Physicians can also satisfy this training by engaging in a total of eight hours of training (inclusive or incremental) on treatment and management of patients with opioid or other substance use disorders. Previous MAT-Waived trainings count towards a DEA registrant’s eight-hour training.

Frequency

This is a one-time requirement.

Deadline

The deadline for satisfying this training requirement is the date of a physician’s next scheduled DEA registration submission – regardless of whether it is an initial registration or a renewal registration – on or after June 27, 2023.

DEA License Renewal Period

Three years.

Cost for DEA Prescriber License to DEA

$888 for three years

Enforcement

Self-attestation on DEA registration form

Penalties

WARNING: 21 USC 843(d), states that any person who knowingly or intentionally furnishes false or fraudulent information in the application is subject to a term of imprisonment of not more than four years, and a fine under Title 18 of not more than $250,000, or both.

Audit

According to the DEA, if audited, prescribers may be asked to show documentation in the form of a certificate that the education was taken in advance of their DEA registration. 

Documentation

DEA recommends that license holders keep documentation on course completion for the eight-hour requirement and readily available if audited.

Notices to DEA License Holders 

An electronic reminder to renew will be sent at 60, 45, 30, 15, and 5 days prior to the expiration date of the registration to the associated email address. All registrants should ensure that the email address listed on their registration is correct and active.

A renewal application is submitted in a timely manner prior to expiration, the registrant may continue operations, authorized by the registration, beyond the expiration date until final action is taken on the application.

DEA allows the reinstatement of an expired registration for one calendar month after the expiration date. If the registration is not renewed within that calendar month, an application for a new DEA registration will be required.

Regardless of whether a registration is reinstated within the calendar month after expiration, federal law prohibits the handling of controlled substances or List 1 chemicals for any period of time under an expired registration.

Multi-State License holders

DEA license holders working in multiple states must have multiple licenses. It is our understanding that you only need to fulfill the educational requirement once.

DEA Registrations Should Use Work Address

If the prescriber uses their home address in application, their home could be subject to unannounced inspections and searches.

State Requirements and DEA

Individual states may have educational requirements to obtain and maintain a valid license in that state. DEA merely requires that all state licensing requirements be met to obtain a DEA registration in that state.

Previous Training

Previously taken accredited courses on opioid and other substance abuse disorders can count towards this requirement. 

Frequency

The training does not have to occur in one session.  It can be cumulative across multiple sessions that equal eight hours.

Questions? Contact Benita Stennis at bstennis@msma.org.