- Practitioner DEA Registration Numbers: Some Anomalies to Note
- May 12, 2014 | Author: Larry K. Houck
- Law Firm: Hyman, Phelps & McNamara, P.C. - Washington Office
Prescriptions issued for controlled substances must contain the patient’s name and address; the drug name, strength and dosage form; the quantity prescribed; directions for use; and the practitioner’s name, address and Drug Enforcement Administration (“DEA”) registration number. DEA advised in its current Pharmacist’s Manual: An Informational Outline of the Controlled Substances Act (Rev. 2010) that pharmacists are responsible for ensuring that prescriptions are issued by appropriately registered or exempt practitioners and that “it is helpful to be familiar with how a DEA registration number is constructed and to whom such registrations are issued.” DEA has taken enforcement action against pharmacies that it believes failed to verify that practitioner registrations were valid and active. Pharmacies have implemented elaborate electronic systems to detect invalid registrations based on DEA’s formula for valid registration numbers. However, pharmacists should be aware that DEA has issued valid practitioner registrations that do not follow the agency’s prescribed formula which would be identified by pharmacy verification systems as invalid.
DEA registration numbers consist of a formulaic combination of nine alpha and numeric characters specific to each registrant. Registration numbers for practitioners (that is physicians, dentists, veterinarians, hospitals and clinics) begin with the letters “A,” “B” or “F.” Mid-level practitioner registration numbers begin with the letter “M.” DEA recently began issuing registrations to U.S. Department of Defense “personal service contractors” beginning with the letter “G.”
DEA has stated that the first letter of the registration number is “almost always followed by the first letter of the registrant’s last name” (for example, “F” for Dr. William Feelgood), then a computer-generated sequence of seven numbers (for example AF1234567). However, when the registrant’s name begins with a number (such as 42nd Street Pharmacy), DEA issues a registration number with a “9” as the second character in place of an alpha character. So, the DEA registration for 42nd Street Pharmacy might be A91234567.
We recently learned that DEA has issued registrations with a second character of “9” to individual practitioners whose last names do not begin with a number. For example, DEA may have issued registration number A91234567 to Dr. William Feelgood. Though very rare, pharmacists should be aware that DEA has issued a handful of such registrations and that these registrations are nevertheless valid.