When it comes to DEA registration — your permission to prescribe, dispense and administer controlled substances — you are justified in asking questions anytime something suspicious happens or a nonsensical situation occurs. After all, you are responsible for protecting your registration and yourself, both personally and professionally. One issue that causes confusion and might raise a red flag is when a pharmacy requests your DEA registration number to fill a prescription for a noncontrolled substance.
A veterinarian I spoke with expressed frustration over prescribing noncontrolled substances and then repeatedly fielding calls from a pharmacy, only to hear, “May I have your DEA registration number?”
“I don’t understand it,” the DVM said. “Why does a pharmacy need my DEA registration number to fill a prescription for an antibiotic? I thought I needed to provide it upon request only if the ordering or prescribing of controlled substances was involved. Could it be a scam? Am I being targeted? And wasn’t this issue addressed years ago, all the way up to the American Veterinary Medical Association?”
The doctor’s questions are valid. The issue has existed for years and has been addressed multiple times by top-ranking veterinary organizations and professionals. Policies have been established. Guidelines have been published. Yet, despite collective best efforts, the topic continues to resurface. The question remains, “Why?”
DEA Registration Numbers
Before diving into the why, let’s cover the basics.
THE WHAT
- Registration numbers are unique identifiers issued to prescribers by the U.S. Drug Enforcement Administration.
- While not publicly posted, a DEA registration number is not privileged information. The Freedom of Information Act provides public access to certain government records through a written request.
- The DEA grants registrations to qualified individuals and entities based on their activity with controlled substances or DEA-listed precursor chemicals used to manufacture controlled drugs.
THE PURPOSE
DEA registration numbers allow for:
- From an oversight standpoint, the number helps document who ordered or prescribed a drug, who received or picked it up, what was ordered or prescribed, where the drug was delivered or picked up, when it was delivered or picked up, and why it was prescribed.
- A DEA registrant must adhere to many requirements and responsibilities.
- Tracking and accountability help prevent drug diversion and other illicit activities.
The Why
Any prescription submitted to a pharmacy for fulfillment is a transaction. Pharmacies handling controlled substances and other drugs must adhere to regulations and internal protocols. Before filling a prescription, a pharmacist’s due diligence includes proper identification of the prescriber.
The “why?” in the conversation above likely arose from the pharmacy’s internal requirement. Before assuming that a pharmacy worker is trying to obtain your DEA registration number for nefarious purposes, remember that verifying a prescriber’s identity is due diligence. Think of numerical identifiers as digital fingerprints.
Industry Action
Years ago, the exclusion of veterinarians from the federal definition of “health care provider” resulted in their having to use a DEA registration number for identification. In 2011, the AVMA approved a policy discouraging prescribing veterinarians from providing a DEA registration number when a transaction did not involve controlled drugs. In 2013, the National Council for Prescription Drug Programs issued new guidance instructing pharmacies and third-party processors to alternatively accept a veterinary state license number for identification purposes with noncontrolled substance prescriptions.
Despite those efforts, prescribing veterinarians still run into situations where a pharmacy asks for a DEA registration number for a noncontrolled substance prescription.
In other words, asking for a DEA registration number is not illegal. At the practitioner level, you don’t have to share it upon a pharmacy’s request involving noncontrolled substances. However, the pharmacy will request another form of identification for verification. You must provide one.
Every DEA registrant is responsible for safeguarding controlled substances and preventing diversion. For pharmacists, verifying that any prescription is accurate and validating its legitimacy is critical to ensure medications are distributed through licit channels.
If you have ongoing interactions with certain pharmacies or pharmacy networks, make sure their computer systems list you as a veterinarian and have all the essential information needed for identification purposes, such as your name, state license number, address and contact information. Being proactive can reduce repeated inquiries.