A question came up today, and I figured it was worthy of a little education out in the field. If you are ONLY prescribing controlled substances at your office, then you can use your individual DEA license to prescribe medications to your patients. However, if you are doing anything other than prescribing - like dispensing, administering, or disposing of controlled substances at your office - then your office needs it own DEA number.
There are several things you need to put into place if you decide to dispense, administer, or dispose controlled substances at your practice. Oh, and be prepared for an unannounced audit by the DEA. We all know how much practitioners LOVE audits, especially the unannounced kind.
Here is the listing of the Rule and Regulations to make sure you and your practice are covered. You will also have to have policies and procedures in place as to the handling of the controlled substances. In case you didn't know, the DEA does not play around with non-compliance.
If you have questions about your prescribing abilities in your state - HERE is a good reference.
Doing anything but prescribing controlled substances in your office, could lead to at minimum a headache not to mention increased initiation and on-going costs. It is probably not something you want to jump right off into when you first open your practice. Research it, talk to a good healthcare attorney, and make sure you have everything on the up and up to keep you out of hot water...and well... jail. You have worked too hard to get to where you are to end up in jail.
If you need a place to send your patient to dispose of their controlled medications - some pharmacies will do it and also some law enforcement agencies will, but not all of them, have the patient call ahead. You can also search the DEA website to find a place near your office or near your patient HERE. Having a list available in your office would be nice, or even put this link on your computer desktop.
You need to update your DEA license if you change addresses. The DEA website is a great reference. It seems to be pretty straightforward and easy to navigate. Their contact information is also listed on their website, and you can never go wrong by giving them a call and asking questions. Keep track of who you talked to, and get any instructions or directions in writing. (I have always been a cover my rear kind of girl).
There is a National Prescription Drug Take Back Day - and that date is also on the DEA website.
Staying in compliance with all the Federal, State and Local laws can be tricky and confusing. If all else fails, spend the money and talk to a healthcare attorney. It will be a tax deduction, so keep the receipt. Have all your questions ready to make use of your time. It would also be a good time to have them look over your consents to make sure you have covered yourself there.
This is just another step in opening your practice, and something to think about. Silver Leaf Practice Management Solutions offers a controlled substance policy if you need one. We can also customize your polices and put them on your letterhead for you. You can view our consents and policies HERE.