DEA Investigations
DEA inspections, controlled substance compliance, and Drug Supply Chain Security Act enforcement.
Reapplying for DEA Registration After Revocation or Surrender
After a DEA revocation or surrender, there is no reinstatement track. Reapplying means a new application judged on the same public…
Legitimate Medical Purpose in Controlled Substance Prescribing
DEA reads a prescriber's own chart against 21 CFR 1306.04's legitimate medical purpose standard. What the record must show, and th…
DEA Registration and Change of Pharmacy Ownership
Why a DEA registration does not travel with a pharmacy sale, what the buyer must apply for, and how the closing has to be sequence…
DEA Diversion Investigator Interviews: What Staff Should Know
What DEA diversion investigators ask pharmacy staff, whether the interview is voluntary, and why counsel for the pharmacy is not a…
DEA Accountability Audits: Challenging a Shortage Finding
How a DEA accountability audit turns purchases, dispensing records and two counts into a shortage finding, and the assumptions a r…
Transferring Controlled Substance Prescriptions Between Pharmacies
Schedule II prescriptions generally cannot transfer between pharmacies. Schedule III-V transfers follow one-time rules under 21 CF…
Mid-Level Practitioner Prescribing Authority Limits
State law, not DEA registration, sets a mid-level practitioner's prescribing authority. What pharmacists and practices need to ver…
Memoranda of Agreement With DEA
What a DEA Memorandum of Agreement resolves, the terms it commonly imposes, and what a breach of those terms means for the registr…
The 5 Percent Distribution Rule for Pharmacies
How the 5 percent rule at 21 CFR 1307.11 lets pharmacies transfer controlled substances without a distributor registration, and wh…