April 19, 2019

Regulatory change on DEA Licenses could cause massive implications to your practice.

Few things can bring your routine clinical practice to a screeching halt as much as a licensure expiration that goes unnoticed or delayed. Most doctors are busy moving fluidly between clinical encounters and do not have the time to keep up with impactful regulatory announcements like the one announced by the Drug Enforcement Agency last year. Physicians get a DEA license because it’s the cost of doing business. A physician is powerless and unemployable without the ability to prescribe.

In the past DEA licensure allowed an informal grace period for renewal, which made missing an expiration date forgiving. The DEA announced changes, effective as of January 1, 2017, to the rules of renewal regarding DEA licensure. For reasons that are unclear, the policy change was posted only on the DEA/DOJ website and effectively eliminated any informal grace period. I.e. miss your DEA license renewal one second past the stroke of midnight on the expiration date and you will have to start all over again from the beginning. The DEA is slated to provide one notice by snail mail about two months prior to expiration of your DEA license. Caveat Emptor: One notice and that’s it! Stay alert and hope it doesn’t get lost amongst the piles of mail you sift through daily.

Fortunately, professional organizations such as the AMA and AOA petitioned the DOJ/DEA to reconsider the unintended consequences to the nearly 1.6 million holders of a DEA license and its implications on patient care nationwide. Want to know the DEA/DOJ new rules? click here

The bottom line: An official one-month grace period has since been designated. The DEA will provide two notices: one by mail and another by email. But the consequences of missing license renewal are still steep.

The DEA fees would be the same, $731, but when paying those heavy fees it’s nicer to fill out a half page renewal application than a multi-page new applicant form. Miss the deadline/ grace period and your old DEA number will be retired forcing a new application process and hence a new DEA number. A new DEA number translates into procuring new prescription pads, updating your state specific controlled substance permits (for a list of states requiring a second controlled substance requirement click here.), and updating/tracking your expired DEA license on all your credentialing documents moving forward.

If that’s not enough, your hospital or clinic may have policies that trigger a loss or suspension of credentials with a lapse in licensure. Ask your in-house credentialing specialist or review your institutional bylaws for details.

You have enough to worry about, don’t add another worry to the list. If you are not sure when your DEA license expires just click here to look it up.

Here are three tips to avoid DEA licensing snafus:
1. Ensure your state medical license is valid and not expired prior to applying for or renewing a DEA license. An expired state medical license can forfeit your application and the DEA fees are non-refundable.
2. Maintain a robust expiration alert system in place to remind yourself and your staff physicians (if you are a medical director). Missed licensure events create pain and frustration that are 100% preventable.
3. Apply or renew a license online. Using snail mail and paper only increases the risk of missed deadlines.

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