CONTROLLED SUBSTANCE EDUCATION REQUIREMENT FOR DEA REGISTRATION
Frequently Asked Questions
Sec. 1263 of the spending bill Congress passed in December 2022 requires controlled substance prescribers to complete 8 hours of one-time training on safe controlled substance prescribing as a condition of receiving or renewing a DEA registration.
What is the requirement you ask? The statutory language is provided by a separate bill, called the Medication Access and Training Expansion Act (or MATE Act).The MATE Act will better equip the health care system to identify, treat, and prevent addiction, as well as improve pain management by educating providers, addressing racial bias, and standardizing training nationwide.
Does this new DEA training requirement affect me?
Likely. The requirement applies to all DEA registration submissions (Schedules II, III, IV, and V)—regardless of whether it is an initial registration or a renewal registration—beginning on or after June 27, 2023. The only exceptions are veterinarians and those who will not be obtaining or renewing a DEA registration.
What am I required to do?
At the time of your next scheduled DEA registration submission (but not before June 27, 2023), registrants must: • Complete eight hours of qualified training on safe controlled substance prescribing. • Check a box on your registration submission affirming that you have completed required training. • Retain copies of all certificates of completion. This applies regardless of whether a registrant is completing their initial registration application or renewing their registration. It also applies to all drug schedules (Schedules II, III, IV, and V).
What is the deadline for satisfying this new training requirement?
•Compliance is required by the time of your next scheduled DEA registration submission— regardless of whether it is an initial registration or a renewal registration—but not before June 27, 2023. For example, if you renew on June 26, 2023, compliance is not required until the next renewal. •This one-time training requirement affirmation will not be a part of future registration renewals
How can I satisfy this new training requirement?
Physicians (MD/DO) and other practitioners can satisfy this training by engaging in a total of eight hours of training on treatment and management of patients with opioid or other substance use disorders from the approved organizations listed below. A few key points related to this training: 1. The training does not have to occur in one session. It can be cumulative across multiple sessions that equal eight hours of training. 2. Past trainings on the treatment and management of patients with opioid or other substance use disorders can count towards a practitioner meeting this requirement. In other words, if you received a relevant training from one of the organizations listed below— prior to the enactment of this new training obligation on December 29, 2022—that training counts towards the eight-hour requirement. 3. Past DATA-Waived trainings count towards a DEA registrant’s 8-hour training requirement. 4. Trainings can occur in a variety of formats, including classroom settings, seminars at professional society meetings, or virtual offerings. Important Items to Note: To qualify, the coursework must meet three criteria: • The course must be an approved topic • The course must be conducted through an approved medium • The course must be delivered by an approved training provider
Does the FAFP offer eligible training on safe controlled substance prescribing?
Yes. The FAFP offers a 2-hour online enduring material course on controlled substance prescribing, and the new federal law specifies that relevant courses offered by the providers will satisfy the requirement. This 2-hour course include CME credit and is free for FAFP members. Note: Past DATA-Waiver trainings count towards a DEA registrant’s 8-hour training requirement. Important: Before taking new courses, note that past trainings from recognized organizations can be used to satisfy requirement. In other words, if you received a relevant training from one of the recognized organizations—prior to the enactment of this new training obligation on December 29, 2022—that training counts towards the eight-hour requirement. DEA has confirmed there is no statute of limitations for past coursework to qualify.
How will DEA enforce this requirement?
DEA has indicated it does not plan to audit or investigate prescribers based solely on compliance with this training requirement. However, the agency may check for certificates of completion when investigating a prescriber for some other infraction.
How do I demonstrate compliance?
Registrants will need to check a box on their DEA registration submission—regardless of whether it is an initial registration or a renewal registration, affirming they have completed the required training. Prescribers should retain copies of all certificates of completion. Recent graduates should contact their medical school for completion certificates, but they will also need to take supplemental training if their qualifying medical school courses total less than eight hours. The DEA currently has no plans to create a platform that will allow prescribers to upload and store certificates of completion.
Will I have to complete the eight hours of training on a cyclical basis?
No. Additional training is not required after the one-time, 8-hour requirement has been satisfied. Sec. 1263 specifically states, “The Attorney General shall not require any qualified practitioner to complete the training…more than once.”
Do recent medical school graduates have to complete this additional training?
Likely. The requirement applies to all DEA registration submissions—regardless of whether it is an initial registration or a renewal registration—beginning on or after June 27, 2023. If you do not intend to apply for a DEA registration, you are not affected.
Do the trainings have to be for continuing education credit?
No. Certificates of completion are required, but formal continuing education credit is not.
I have multiple DEA registrations. Do I have to complete eight hours of training for each one?
No. The same eight hours of training can be recycled for multiple DEA registrations
Do I have to use specific training providers?
Yes. The course(s) must be provided only by the organizations listed in the statute. Training must be provided by or approved by one of the following organizations: 1. The American Society of Addiction Medicine 2. The American Academy of Addiction Psychiatry 3. The American Medical Association 4. The American Osteopathic Association 5. The American Dental Association 6. The American Association of Oral and Maxillofacial Surgeons 7. The American Psychiatric Association 8. The American Nurses Credentialing Center 9. The American Association of Nurse Practitioners 10. The American Academy of Physician Associates 11. Any other organization accredited by the Accreditation Council for Continuing Medical Education (ACCME) or the Commission for Continuing Education Provider Recognition (CCEPR) 12. Any organization accredited by a State medical society accreditor that is recognized by the ACCME or the CCEPR 13. Any organization accredited by the American Osteopathic Association to provide continuing medical education 14. Any organization approved by the ACCME, or the CCEPR
Will training completed prior to the law’s passage count toward the new requirement?
Yes. Past trainings from designated training organizations can count towards a practitioner meeting this requirement. In other words, if you received a relevant training from one of the recognized organizations—prior to the enactment of this new training obligation on December 29, 2022—that training counts towards the eight-hour requirement. DEA has confirmed there is no statute of limitations for past trainings to satisfy the requirement. Certificates of completion are required.
Does the eight hours of training have to occur in one session?
No. The training does not have to occur in one session. It can be cumulative across multiple sessions that equal eight hours of training.
How does the removal of Data Waiver (X-Waiver) affect me?
To learn about the Removal of DATA Waiver (X-Waiver) Requirement, click here.
How does the removal of Data Waiver (X-Waiver) affect me?
For outside resources related to treatment and management of patients with opioid or other substance use disorders, click here.