DEA Reverses Announced Change to Registration Renewal Process
December 21, 2016
We recently alerted the Federation to a notice from the Drug Enforcement Administration (DEA) that effective January 1, 2017, the DEA was changing its long-standing policy of allowing a grace period for registrants who failed to file a timely renewal application. Late yesterday afternoon, the DEA reversed its decision and posted a notice that it is retaining its current policy and procedures, with one minor change, regarding registration renewals. The revised announcement states the following:
REVISED ANNOUNCEMENT REGARDING RENEWAL APPLICATIONS
Starting January 2017, DEA will no longer send its second renewal notification by mail. Instead, an electronic reminder to renew will be sent to the email address associated with the DEA registration.
At this time, DEA will otherwise retain its current policy and procedures with respect to renewal and reinstatement of registration. This policy is as follows:
- If a renewal application is submitted in a timely manner prior to expiration, the registrant may continue operations, authorized by the registration, beyond the expiration date until final action is taken on the application.
- DEA allows the reinstatement of an expired registration for one calendar month after the expiration date. If the registration is not renewed within that calendar month, an application for a new DEA registration will be required.
- Regardless of whether a registration is reinstated within the calendar month after expiration, federal law prohibits the handling of controlled substances or List 1 chemicals for any period of time under an expired registration.
So, the good news is that registration numbers will not automatically be retired if renewal applications are filed within the one-month grace period after the expiration date. However, there are a few issues that need clarification from the DEA, including whether the filing of a renewal application during the one-month grace period automatically reinstates the registration number or whether DEA must adjudicate the renewal application before the number becomes valid. It also is not clear whether a registration number remains valid if the registrant files a renewal application during the grace period and DEA fails to adjudicate the application before the end of the month. The AMA will be following up with DEA staff on these issues and will update the Federation accordingly.
If you want to check your registration expiration date, please contact the DEA Registration Service Center at 1-800-882-9539 or email DEA.Registration.Help@usdoj.gov and include your DEA Registration number in your email. For questions about this alert, please contact Debra Cohn, Senior Washington Counsel, at (202) 789-7423 or firstname.lastname@example.org.
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