Must I Obtain 2 DEA Numbers if I Am Going to Practice in 2 States?

Carolyn Buppert, NP, JD


February 04, 2011


I live near a state line and practice in 2 different states. Is it necessary to have a different DEA number for each state?

Response from Carolyn Buppert, NP, JD
Attorney, Law Office of Carolyn Buppert, PC, Bethesda, Maryland

Yes, if you prescribe controlled substances in 2 states. Here is what the Drug Enforcement Administration (DEA) says on that matter:

DEA individual practitioner registrations are based on a State license to practice medicine and prescribe controlled substances. DEA relies on State licensing boards to determine that practitioners are qualified to dispense, prescribe or administer controlled substances and to determine what level of authority practitioners have, that is, what schedules they may dispense, prescribe, or administer. State authority to conduct the above-referenced activities only confers rights and privileges within the issuing State; consequently, the DEA registration based on a State license cannot authorize controlled substance dispensing outside the State. [1]

The DEA elaborated in another publication as follows[2]:

Please be aware that practitioners who wish to administer, dispense, or prescribe controlled substances in multiple states have the following options regarding a DEA registration:
  1. Practitioners will need to obtain a separate DEA registration in each state where they plan to administer, dispense, or prescribe controlled substances.

  2. If the practitioners will be working solely in a hospital/clinic setting, they may use the hospital's DEA registration instead of registering independently with DEA if the hospital agrees and the situation warrants. 21 C.F.R. § 1301.22(c).

  3. Alternately, under 21 C.F.R. § 1301.51, practitioners may transfer their existing DEA registration from one state to another as needed by contacting DEA's Registration and Program Support Section at 1-800-882-9539 or request the change online at DEA will investigate each modification of registration as if it was a new application. DEA will issue a new DEA certificate with the appropriate changes if DEA approves the modification.

  4. DEA has provided a limited exception to this requirement in that practitioners who register at one location in a state, but practice at other locations within the same state, are not required to register with DEA at any other location in that state at which they only prescribe controlled substances. 21 CFR § 1301.12(b)(3).