Dentists with DEA registration must comply with new federal act requiring opioid use disorder training

CDA course, relevant dental school instruction can be applied toward training requirement
March 21, 2023
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Quick Summary:
March 29 update: A DEA letter to registrants outlines the training requirements of the federal Medication Access and Training Expansion Act, which requires DEA registrants to complete eight hours of training before initial DEA registration or by the first renewal of registration occurring on or after June 27. The letter confirms that a CDA course and ADA courses on opioid prescribing and pain management can be applied toward the federally required training. Relevant dental school instruction also satisfies the training requirement.

Dentists, physicians and other authorized prescribers across the U.S. will be required under a new federal law to complete eight hours of instruction on treating and managing patients with opioid and other substance use disorders prior to renewing or obtaining a DEA registration.

March 29 update: The U.S. Drug Enforcement Administration this week sent a letter to DEA registrants outlining the training requirements of the Medication Access and Training Expansion Act passed in the Omnibus Bill of 2022, including how DEA registrants can satisfy the federal training requirement. The training must be completed before DEA registration or by the first renewal of DEA registration occurring on or after June 27, 2023.

The letter confirms two points not known when CDA first published this article last week: (1) the CDA course “Responsibilities and Requirements for Prescribing Controlled Substances (Schedule II Opioid Drugs),” and relevant courses offered by ADA and CCEPR-accredited providers can be applied toward the federally required eight hours of training; and (2) dentists who completed the CDA course or other eligible courses prior to the act’s enactment can apply the courses’ hours toward the federal training requirement.

Mandated training is a one-time requirement for DEA registrants

The following requirements apply to all prescribers, with exception of veterinarians:

  • Only prescribers who are renewing their DEA registration or who intend to register with the DEA are required to complete the training.
  • The training must be completed before DEA registration or by the first renewal of DEA registration occurring on or after June 27, 2023.
  • The training is required to be completed only once; it will not need to be repeated nor will additional training be required before subsequent renewals of DEA registration.
  • The eight hours of training do not need to be completed through a single course.
  • The course must focus on “the treatment and management of patients with opioid or other substance use disorders.”

Beginning June 27, practitioners will be required to check a box on their online DEA registration form affirming that they have completed the new training requirement regardless of whether they are completing their initial registration application or renewing their registration.

Relevant courses offered by CDA, ADA, CCEPR-accredited providers meet requirement

The federal law specifies that training provided through the American Dental Association, organizations accredited by the Commission for Continuing Education Provider Recognition (CCEPR) or “any other organization the Secretary determines is appropriate for purposes of this clause” will satisfy the training requirement for dentists.

The DEA’s March 27 letter to prescribers also confirms that, in addition to trainings provided by the ADA, “any other organization approved or accredited by the Assistant Secretary for Mental Health and Substance Use, the ACCME, or the CCEPR” will meet the new requirement.

Therefore, dentists can apply CDA’s course “Responsibilities and Requirements for Prescribing Controlled Substances (Schedule II Opioid Drugs),” which already satisfies the Dental Board of California’s new opioid-prescribing C.E. requirement, toward the federal training requirement, as the federal law does not prevent a prescriber from using the same training to satisfy the federally required training and training “for another purpose, such as satisfying State licensing requirements.”

Other relevant courses offered by CDA in the future could also be applied toward the federal training requirement.

Additionally, the letter confirms that “past trainings on the treatment and management of patients with opioid or other substance use disorders can count towards a practitioner meeting this requirement,” meaning dentists who completed the CDA course or another eligible course from an eligible provider prior to the enactment in December 2022 of the new training are permitted to apply those course hours toward the eight-hour training requirement. 

The following courses offered by ADA can also be applied toward the federal training requirement. Most of these courses are free to tripartite members:

Relevant instruction meets training requirement for recent graduates

Relevant dental school coursework will count toward the federally required training for individuals who graduated from dental school fewer than five years ago. All first-time DEA registrants must satisfy the C.E. requirement by the time they register.

Read the DEA letter and find additional information on the Department of Justice website. Learn more about or register for CDA’s course on opioid prescribing and pain management, which is available to CDA members at a significantly discounted price.

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