Traveling with Controlled Drugs (DEA)

July 2012

WSVMA meets with local DEA office about veterinary registrations

Members were recently made aware of concerns in California regarding potential changes in the DEA’s enforcement of the Controlled Substances Act (CSA). Veterinarians in the Sacramento area were contacted by the regional DEA office and asked to confirm that their DEA license was associated with a residence. During the course of that contact, the veterinarians were reminded that federal regulations prohibited them from carrying controlled drugs out of the location associated with their DEA registration. Of course, such a prohibition would prevent many veterinary practices from being able to serve their patients and clients.

The WSVMA recently met with the DEA to discuss the issue and how it affects local veterinarians. According to the Seattle DEA office, there has been no change in their interpretation or enforcement of the CSA. The DEA understands that the CSA does not really take into consideration the unique aspects of veterinary medicine that require more flexibility in the regulations.

The AVMA has been working with DEA officials in Washington, D.C. to address this issue. Federal legislation may be forthcoming, although it’s expected to take quite some time. If federal legislation is introduced, the WSVMA and AVMA will look to members for grassroots support for passage.

What can (or should) members do at this time? There is no need to change practices or procedures regarding DEA registration and recordkeeping or administration/dispensing of controlled substances. This is a reminder, however, to review those practices and procedures to ensure that they are in compliance. If you list your residence as the address associated with your DEA registration and you receive a request to confirm that information, complete the confirmation form and return it as directed. If you receive any communication from the DEA office that is of concern to you or you have questions regarding compliance with regulations, please notify the WSVMA.

April 2012

A message from the AVMA regarding DEA enforcement:

The AVMA was recently made aware of concerns in California regarding potential changes in the DEA’s enforcement of the Controlled Substances Act. Veterinarians in the Sacramento area were contacted by the regional DEA office and asked to confirm that their DEA license was associated with a residence. During the course of that contact, the veterinarians were reminded that federal regulations prohibited them from carrying controlled drugs out of the location associated with their DEA registration.

Of course, such a prohibition would prevent many veterinary practices from being able to serve their patients and clients. According to the national DEA office, there has not been a change in the DEA’s interpretation or enforcement of the CSA. The review of registration applications in California appears to be the result of a regional office confirming that the applicant’s principal place of business was indeed a residential address. It is a fact that the Controlled Substances Act (CSA) is written with this prohibition in place, but the AVMA has historically been informed that 1) the veterinary profession is generally not a target of enforcement in this area; 2) the DEA understands that the CSA does not really take into consideration the unique aspects of veterinary medicine that require more flexibility in the regulations; and 3) it will require a statutory change (i.e., federal legislation) to address the issue.

A subcommittee of the AVMA’s Council on Biologic and Therapeutic Agents (COBTA) has been tasked with evaluating this and other DEA-related issues. Our Scientific Activities and Governmental Relations Divisions have held a number of face-to-face meetings with DEA administrators to address the profession’s concerns. The California Veterinary Medical Association (CVMA) has requested a meeting with the area office and will keep us informed of the outcome. We are currently drafting a letter to the DEA Administrator to ensure the profession's concerns are formally on record. At the same time our DC staff will coordinate a letter to Congress, which we anticipate will also be signed by the state VMAs and allied organizations, addressing the need for a change to the CSA.

What can (or should) members do at this time? There is no need to change practices or procedures regarding DEA registration and recordkeeping or administration/dispensing of controlled substances. This is a reminder, however, to review those practices and procedures to ensure that they are in compliance. If you list your residence as the address associated with your DEA registration and you receive a request to confirm that information, complete the confirmation form and return it as directed. If you receive any communication from your area DEA office that is of concern to you or you have questions regarding compliance with regulations, please notify the WSVMA. If federal legislation is introduced, the AVMA will look to members for grassroots support for passage. If you’re not already a member, consider joining the AVMA Congressional Advocacy Network.

The AVMA will continue to post updates as more information becomes available.

Available resources on the AVMA website:
Veterinary compliance with the DEA and the Controlled Substances Act
Do you need a DEA registration?
Veterinary Practitioners’ Guide to DEA Recordkeeping Requirements
Veterinary Practitioners’ Guide to DEA Security Requirements

 

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