{"id":77858,"date":"2025-06-01T00:00:26","date_gmt":"2025-06-01T04:00:26","guid":{"rendered":"https:\/\/todaysveterinarybusiness.com\/?p=77858"},"modified":"2025-06-01T14:38:40","modified_gmt":"2025-06-01T18:38:40","slug":"dea-registration-lets-talk-drugs-0625","status":"publish","type":"post","link":"https:\/\/navc.sitepreview.app\/todaysveterinarybusiness.com\/dea-registration-lets-talk-drugs-0625\/","title":{"rendered":"Risks and Rewards"},"content":{"rendered":"

You might have heard this statement: \u201cHaving a DEA registration is a privilege, not a right.\u201d What you are less likely to hear is this: \u201cWhen your personal DEA registration is used to order controlled substances, you are personally responsible for everything that happens with those drugs.\u201d I would amend the first line to state: \u201cHaving a DEA practitioner registration is a privilege that comes with responsibility and can lead to significant personal risk when used to order controlled substances for activities that go beyond individual personal practice.\u201d<\/p>\n

When your personal DEA registration is used beyond its intended scope, problems can add up quickly, leading to serious consequences.<\/p>\n

Here are three situations I\u2019ve seen.<\/p>\n

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  1. A veterinarian ordering controlled substances while working as a medical director at a corporate-owned hospital was terminated without warning. All the controlled substances remaining in the hospital\u2019s inventory had been ordered using the veterinarian\u2019s personal DEA practitioner registration. Corporate leadership illegally took possession of the inventory after the DVM\u2019s termination and allowed the drugs to be administered to patients. Legal counsel and law enforcement helped the veterinarian regain possession.<\/li>\n
  2. A veterinarian provided part-time relief services at an animal shelter. The shelter owner had asked the doctor to use their DEA registration to order controlled substances so that operations could continue after the medical director suddenly left. The DVM agreed to do it just once. A falling-out occurred shortly afterward, and the shelter owner fired the relief veterinarian and continued using the doctor\u2019s DEA registration, unbeknownst to the DVM. Months later, the U.S. Drug Enforcement Administration discovered during a routine inspection that all the controlled substances on-site belonged to the former relief veterinarian, who had never been an actual employee and had not been physically present for a while. The DVM was held responsible for abandoning a controlled substance inventory, a severe violation. Legal experts helped sort out the matter. The veterinarian avoided jail time and a six-digit fine.<\/li>\n
  3. A newly graduated veterinarian who recently obtained a DEA registration worked one to two days a week at a clinic while searching for a full-time practice position. The clinic owner asked the doctor to order controlled substances using their personal DEA registration \u201con an interim basis\u201d because the DEA registrant of record had left. The graduate agreed. During our conversation, I learned that over seven months had passed and that no new registrant of record had been hired. The young DVM asked the owner to provide copies of the drug invoices and to stop using the DVM\u2019s registration. The owner refused and locked the veterinarian out of the clinic. Legal counsel and law enforcement were engaged to return the controlled substance inventory to the doctor.<\/li>\n<\/ol>\n

    Here Today, Gone Tomorrow<\/h3>\n

    Employee turnover has escalated<\/a> over the years as corporations and private groups merge and acquire veterinary practices. Many of the departures involve veterinarian DEA registrants who had been ordering and maintaining a controlled substance inventory on behalf of their hospitals. They then transitioned out, and a new DEA registrant moved in.<\/p>\n

    You might ask, \u201cMergers and acquisitions take place all the time, so why does it matter?\u201d The big deal involves the DEA registrant of record.<\/p>\n

    A controlled substance inventory isn\u2019t automatically rolled into a practice sale or merger. Attorneys handling a sale on behalf of either party should ensure that any remaining controlled drugs and all supplier accounts are transferred and updated correctly.<\/p>\n

    From a business standpoint, who legally owns the hospital, organization or corporation doesn\u2019t matter. In the DEA\u2019s eyes, the controlled drugs are legally owned by the individual or entity whose registration number was used on the order. Who paid the invoices doesn\u2019t matter. The privilege of holding a DEA registration comes with responsibilities that must be adhered to.<\/p>\n

    Among the countless veterinarians I\u2019ve had the pleasure to meet or work alongside, never once has someone said they \u201cpreferred\u201d using their personal DEA registration to order controlled drugs on behalf of a large hospital or organization. Veterinarians who end up in situations like the ones I described earlier almost always say, \u201cThere was no other option\u201d or \u201cWithout me, they would have been forced to close the practice.\u201d<\/p>\n

    If you\u2019re thinking, \u201cThat\u2019s just an excuse,\u201d you\u2019re wrong. It\u2019s an unfortunate fact in veterinary medicine and a sad truth for many practitioners.<\/p>\n

    The Risk<\/h3>\n

    I\u2019ll sound like a broken record when driving home this point: If you are a licensed veterinarian with an individual DEA practitioner registration and you use it to order controlled substances on behalf of a facility or organization, you must understand all the risks. The DEA doesn\u2019t show empathy or award a consolation prize if you make decisions based only on what you think is in the best interest of patients. In the DEA\u2019s eyes, you are ultimately the responsible party for everything that happens with a controlled substance inventory. You must consider the stakes and ask the right questions.<\/p>\n

    The Right Questions<\/h3>\n

    If you are considering allowing your personal DEA registration to be used to order controlled drugs on behalf of a practice, organization or another operation for which you are not the primary owner or decision maker, stop and do your due diligence. Ask these questions:<\/p>\n