Marilyn W. Edmunds, PhD, CRNP

Disclosures

December 21, 2004

Question

I work part-time for a family practice office, and I will soon work part-time for a different family practice office in a nearby city as well. I know that I have to have a separate practice agreement for each office, but must I have 2 US Drug Enforcement Administration (DEA) numbers? I was told that my DEA follows my whole life, wherever I go, and stays the same, so I am unsure. Can you clarify this for me?

Response from Marilyn W. Edmunds, PhD, CRNP

State law dictates what you are required to do regarding a practice agreement. This varies considerably from state to state, and I would encourage you to speak with the Advanced Practice Consultant with your Board of Nursing about this.[1] If the new practice is totally different from the old practice and none of the same physicians are involved, you would probably need to have 2 practice agreements.

DEA numbers are a different issue. Requirements are dictated by both state and federal policy. When you apply for a federal DEA number, the resulting number that you receive from the DEA office is site-specific. If you are going to be prescribing or dispensing controlled substances at sites in different states or cities, you would need to have 2 separate DEA numbers. If you are not prescribing and dispensing controlled substances at both sites, or if you are practicing at 2 different sites in the same city, you would need to contact the state office of the DEA, let them know that you are going to be adding a practice location, and ask how that should be handled. There is significant state-to-state variation in what is required.

The DEA previously published a booklet with the requirements for "MidLevel Prescribers." This has been replaced by extensive information published and updated on the DEA Web site.[2] Because your situation is somewhat unique, you will want to contact the federal DEA by calling 1-800-882-9539. They will give you the number for the state DEA office you should contact to learn about specific state requirements.

If you decide that you need to apply for a second DEA number, you may do this by applying through the DEA's Diversion Control Program Website. You will need to provide documentation of your new practice address, a copy of your state license, and a copy of your State Controlled Substance Certificate with the new address. You will be required to pay $390 for each DEA application. Upon approval, you will be sent a second DEA number.

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