DEA Posts Significant Change to Registration Renewal - McDermott Will & Emery

DEA Posts Significant Change to Registration Renewal

Overview


In Depth


The US Department of Justice Drug Enforcement Administration (DEA) recently posted to its website notice of a significant change to its registration renewal process. This change eliminates the informal grace period which the DEA had previously allowed registrants to renew their registrations.

The DEA announced that, starting January 1, 2017, it will send only one renewal notification to each registrant. The renewal notification will be sent to the registrant’s “mail to” address approximately 65 days prior to the expiration date. No other reminders will be provided by DEA.

Most significantly, the DEA noted that a failure to file a renewal application by 12 am EST of the expiration date will result in the “retirement” of the registrant’s DEA number. Any registrant who fails to meet the deadline will be required to apply for a new DEA registration and will receive a new DEA registration number.

In addition to the direct implications for any registrant who fails to renew in a timely fashion, this change in DEA’s longstanding approach will also have implications for pharmacies and others in the supply chain. All such entities, which are required to validate DEA numbers in the ordinary course of performing their own roles, will need to exercise additional diligence.