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Not registering with DEA may be an option for dentists

Dentists should consider potential impacts of registration versus nonregistration

August 10, 2020 2913

Dentists who do not prescribe, administer or dispense controlled substances may choose not to register or reregister with the U.S. Drug Enforcement Agency. DEA registration is not required to write prescriptions for antibiotics, fluoride and other noncontrolled substances.

Dentists who do not prescribe, administer or dispense controlled substances may choose not to register or reregister with the U.S. Drug Enforcement Administration. DEA registration is not required to write prescriptions for antibiotics, fluoride and other noncontrolled substances.

DEA registration is good for three years for dentists after they pay the required fee. But effective Oct. 1, that fee will increase from $731 to $888, leaving many dentists contemplating whether they need to renew their registration or register at all, particularly as they continue to grapple with the increased costs of running a practice during the pandemic.  

Fewer dentists are estimated to be prescribing controlled substances since dental schools and continuing education are emphasizing the “stepwise recommendation,” a dental pain management tool published in the 2015 ADA Practice Guide to Substance Use Disorders and Safe Prescribing, which calls for ibuprofen or a combination of ibuprofen and acetaminophen depending on the degree of pain and other considerations. 

Dentists may want to consider the additional regulatory requirements as part of having a DEA registration as well as the potential impacts of going without one. Some dental plans require DEA registration in their credentialing process, for example.

Mandatory CURES consultation, other requirements for DEA registrants

A separate DEA registration is required for each location where a dentist dispenses or administers controlled substances, meaning that an oral surgeon with more than one practice location will have a DEA registration and pay a fee for each location. 

In addition to the fee, DEA registration comes with other requirements that are intended to reduce prescription fraud, including the abuse of opioids, and adverse events caused by handwriting errors.

All dentists with DEA numbers not only must register for California’s Controlled Substance Utilization Review and Evaluation System, known as CURES 2.0, but must also, with just a few exceptions, check a patient’s prescription history in the system before prescribing a Schedule II-IV substance. The law requiring CURES consultation took effect October 2018.

Dentists in California must also discuss with a minor or the minor’s parent or guardian the potential risks associated with opioid medications prior to prescribing the medication in nonemergency circumstances.

And beginning January 2022, health care practitioners authorized to issue all controlled and noncontrolled prescriptions must have the capability to transmit prescriptions electronically. Pharmacies will be required by the same law to have the ability to receive the electronic transmissions. 

Dental plans may require DEA number for credentialing, recredentialing

When a dentist applies to be part of a dental benefit plan’s network of providers, the plan may ask for the dentist’s DEA number. Additionally, a dentist who is already a contracted provider with a plan may be asked to provide their DEA before they can be recredentialed by the plan. 

Before choosing not to obtain a DEA number, dentists should verify with the plan if a DEA number is required to join the plan’s network or to remain a contracted provider within the network. 

The American Dental Association last week reported that it has asked the DEA to delay implementing the increased registration fee to assist dental practices that are impacted financially by the COVID-19 pandemic. CDA will update members should the DEA delay its new fee schedule.

See the CDA Practice Support resource “Controlled Substances Prescribing and Dispensing” for more information about DEA registration, electronic prescribing of controlled substances and more.