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Part Two: Don't Let the DEA be Your Downfall

Part Two: Don't Let the DEA be Your Downfall

DEA and the Locum Tenens Physician

The common misconception that a Drug Enforcement Administration (DEA) certificate allows a provider national permission to prescribe anywhere will often derail the timeline when trying to get a locum tenens provider working on assignment.

Separate registration for each place of professional practice is granted by the state in which a practitioner practices. Governed by the U.S Department of Justice, the Office of Diversion Control establishes the policies for the prescribing of controlled substances. Facilities and principals where controlled substances are stored, administered, or dispensed by a person, adhere to the guidelines of this office. Therefore, locum physicians who practice and prescribe in multiple states, may need multiple registrations.  

 

When a State License Won’t Cut It

DEA is as critical as the state license and many processes hinge on the provider having an active DEA in the state of the assignment. The majority of medical staff credentialing and financial credentialing at a Medical Staff Office (MSO) require an active DEA in the state of practice. While some institutions will continue to process an application with the DEA pending, by-and-large, most will not.

 

Practicing at Multiple Locations in the Same State

As with most rules and regulations, there are exceptions. Practitioners who register at one location in a state and also practice at another site(s) in that same state, are not required to register with the DEA for those other locations unless they maintain and dispense a supply of controlled substances for direct distribution. Be aware that there is a difference between distribution and direct distribution. For example, the agency defines distribution to include prescribing of the substance, whereas direct distribution would include on-site pharmacy, and in some cases, the direct distribution of samples.

 

Practicing Outside the State of Registration

It may seem confusing initially, but since it is commonplace for a locum physician to practice in multiple states, there are several options for providers who work in more than one state.

  1. The provider acquires a separate DEA in each state where they plan to practice.
  2. If hospital based, the provider can use the hospital/clinic DEA registration instead of obtaining an individual DEA if appropriate or deemed warranted.
  3. The provider temporarily transfers their existing DEA from one state to another.

The third route is the one most often used in locum tenens situations as it seems to be the easiest and most time efficient. Yet, there are a few factors that may make it more effective to apply for a new DEA in the state needed.

 

Which DEA Registration Option is Best?

Friendly reminder here that timing is everything! First, consider whether this is a long-term, continual assignment, or one that will just be a few days at a time. When a provider is only working a few days and then returning to their “regular” practice in another state, the DEA would need to be transferred back-and-forth which would take a couple of weeks (on average,) each time that needs to be done. 

Secondly, when applying to payers for financial credentialing, they most likely will be checking to see if the physician has a DEA in the state of service. I’ve seen it happen time and time again where payer application credentialing occurred after the doctor had transferred their DEA back to another state and thus, payer participation was denied. To avoid these follies, I’m under the opinion that one should apply for a new DEA each time if at all possible.

Is the physician already licensed in the state? DEA transfer of permanent application cannot be initiated until the physician is licensed in the state they request registration in. If you are already running tight on licensure, the quickest way is to transfer, but you still may consider additional permanent application for the next assignment.

DEA transfers are typically about half the time of a permanent application, but are by no means instantaneous. Remember to account for this when determining whether the candidate and dates needed will align and the whole process of getting a locum provider to work will go much more smoothly.

Office of Diversion Control questions can be answered at their website www.deadiversion.usdoj.gov. You may also ask your recruiting consultant if you need more information.

 

Arlene Macellaro is the VP of Business Development and Client Relations for All Star Recruiting. She can be reached at AMacellaro@allstarrecruiting.com.

"When I was initially contacted by All Star, I had already been approached by several companies and presented to quite a few opportunities so I didn't think I needed to speak to another firm. What I didn't count on was All Star having another eight positions which other agencies didn't have. Now I'm happily working at one of the options they offered. Thanks!"
- Bal A., M.D.

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