On June 27, 2023, an updated Drug Enforcement Administration (DEA) opioid training requirement took effect, impacting optometrists both applying for and renewing a DEA registration.
This article examines the new requirement, walks through the entire application and renewal process, provides a checklist of necessary documents, and outlines the attestation instructions.
Included in this guide is a comprehensive list of accredited free courses and a summary of US states with controlled substances laws which will ensure DEA compliance and empower optometrists to exercise their full prescribing privileges in each state.
The history of the DEA
The DEA was created in 1973 to enforce the laws and regulations of controlled substances in the United States.1
Title II of the Comprehensive Drug Abuse Prevention and Control Act of 1970 contains the Controlled Substances Act (CSA), a statute that places all substances into schedules or categories based on medical use, potential for abuse, and safety.2
DEA licensure
All healthcare professionals, including optometrists licensed to dispense, administer, or prescribe controlled substances, must register with the DEA’s Diversion Control Division for a DEA Registration Number.
This unique identifier is used for authenticating and tracking controlled substances.3
New opioid training requirement
Recently, the Consolidated Appropriations Act of 2023 enacted a new one-time, 8-hour training requirement for DEA-registered practitioners regarding the treatment and management of patients with opioid or other substance use disorders.
By June 27, 2023, upon renewal or new registration, DEA providers must attest to the completion of this 8-hour training requirement.4
Training courses by DEA-accredited groups
The DEA points out that the 8-hour education can be completed virtually, in person, and in more than one session as long as the instruction is presented by a DEA-accredited group.5
The following are courses given by accredited groups that meet all requirements:
- The Providers Clinical Support System (PCSS) provides free 8-hour training options, available either online, in-person, or through live webinar sessions.6
- The American Medical Association Education Hub (AMA Ed Hub) delivers free training courses to satisfy the DEA requirement. They offer 25.25 hours of online continuing education (CE) that can be taken in any combination to fulfill the 8-hour requirement.7
- The New England Journal of Medicine (NEJM) Knowledge+ platform offers a free 10-hour continuing education course on the treatment and management of patients with opioid or other substance use disorders.
- The NEJM advertises that its online content is streamlined for learning with resources such as downloadable summary PDFs. A case-based test with 62 questions is given at the end for the completion of credits.8
- The American Society of Addiction Medicine (ASAM) produces paid e-learning courses and 9.5 free CE hours that satisfy the training criteria.9
- The American Academy of Addiction Psychiatry (AAAP) endorses instruction through PCSS mentioned above.10
- The American Academy of Physician Associates (AAPA) is granting two free complete training courses to all providers, with one available until the end of June 2024 and the other until the end of November 2024.11,12,13
Download the DEA License Application Checklist here
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DEA License Application Checklist
Use this DEA license application checklist to collect the required information and track the progress of your application.
DEA license pre-application
To avoid any delays, a couple of items should be in place prior to submitting an application for DEA licensure.
State Controlled Substance Registration (CSR)
Check your state’s controlled substances license requirements. The DEA mandates that all state licensing requirements must be met before obtaining DEA registration for that state.14
Almost half of all US states require a CSR certificate to prescribe controlled substances. In these states, along with an optometric license, it is necessary to apply for the CSR license and have it in place, or at least pending approval, before applying for a DEA license.
The following states require CSRs for optometrists with controlled substance prescribing authority:15
- Alabama
- Connecticut
- Delaware
- Idaho
- Illinois
- Indiana
- Iowa
- Louisiana
- Massachusetts
- Michigan
- Missouri
- Nevada
- New Jersey
- New Mexico
- Oklahoma
- Rhode Island
- South Carolina
- South Dakota
- Texas
- Utah
- Wyoming
Email address
Since May of 2022, all new applications and renewals for DEA registrations have been submitted electronically. Registrants must have a current and active email address listed.
The DEA will verify the email address before proceeding with the application process.16
Attestation
New and renewing practitioners will be required to check a box on the online DEA registration form.5
The attestation instructions are outlined below:17
- During the registration or renewal process, an attestation screen will pop up with specific requirements. The verbiage will vary depending on the type of application. Check the applicable criteria and click “Okay.”
- The pop-up should disappear, replaced by information and terms. Click the box indicating that the information has been read and understood. Then click “Continue.”
You have attested! From this point, the application process progresses to the different sections described below.
Check out the DEA License Application Checklist to track your progress
DEA application sections and checklist
Individual/business information
This first section deals with basic identifying information.18
Individual registrations
Personal applicants will be asked to fill in the following:
- Full name
- Address
- Phone number
- Email address
- Social security number
- Date of birth
- Optometry school information
- Graduation year
- National provider identification (NPI) number
- Enter “OD” in the “Professional Degree” area
Business registrations
To register for a practice, alternate information consists of:
- Business/practice name
- Address
- Tax ID number (TIN)
- Business/practice phone number
- Contact person information
Business activity
The Code of Federal Regulations recognizes optometrists as mid-level practitioners (MLPs) who are permitted to work with controlled substances in the state of practice.
Each state has specific schedules for MLPs:19
- New applicants: New applicants should check the “mid-level practitioner (MLP)” box.
- Renewals: For renewals, there is an option to register for the same drug schedule(s) or request a change that is allowable in the state of practice. Skip to Section 4.
Drug schedules
New applicants will be asked to choose the drug schedule(s), according to state prescribing laws. Renewing licensees will be given the option to keep or change drug schedules, per state prescribing statutes.18
For drug selection guidelines, the DEA has a listing of MLP drug schedule authorizations by state.
Listed below are the various drug schedules:
- Schedule 2 Narcotic
- Schedule Non-Narcotic (2N)
- Schedule 3 Narcotic
- Schedule 3 Non-Narcotic (3N)
- Schedule 4
- Schedule 5
State license(s)
Licenses reported in this section must be valid and active. If your state mandates a CSR, both the optometric and CSR licenses should be documented. In states that do not require CSRs, only the optometric license is necessary.18
The license information includes:
- State of licensure
- Optometric license number with expiration date
- State CSR license number with expiration date if applicable
Liability
Individuals and businesses are required to reveal (1) past federal or state convictions related to controlled substances, (2) exclusion from Medicare or state programs, and (3) surrender, revocation, suspension, restriction, denial, or pending action of a federal or state controlled substance registration.18
For any affirmative answers, reference each one separately with the liability question number and disclose the:18
- Date of the occurrence
- Incident location
- Nature of the circumstances
- Disposition or resolution of the event
Application fee exemption
In individual cases, this portion will not be pertinent unless the business is a governmental institution exempt from administration charges. If this does not apply, move on to the next section.18
Payment
The non-refundable registration fee for renewals and new applicants is $888 for 3 years.20
The following credit cards are acceptable forms of payment:18
- American Express
- Discover
- MasterCard
- Visa
Signature
All information can be reviewed, edited, and updated before submission. Once the electronic signature is accepted, the registration process is complete.18
Conclusion
Whether applying for the first time or renewing a current DEA license, optometrists must attest to completing the new 8-hour opioid training requirement. This article has offered many no cost educational options to fulfill the DEA mandate.
Also, by understanding specific state laws regarding controlled substance registration requirements and drug schedules prior to applying for DEA licensure, optometrists can ensure a smooth application process, allowing the practice of optometry with the fullest prescribing authority possible.
