April 11, 2019

QUESTION:        Can a physician use a hospital’s DEA registration number to administer, dispense or prescribe controlled substances to patients at the hospital?


ANSWER:            Yes, physicians who are agents or employed by the hospital may, when acting in the usual course of business or employment, administer, dispense, or prescribe controlled substances under the registration of the hospital by which they are employed.  However, it is required that (1) the dispensing, administering, or prescribing is in the usual course of professional practice; (2) practitioners are authorized to do so by the state in which they practice; (3) the hospital has verified that the practitioner is permitted to dispense, administer or prescribe controlled substances within the state; (4) the practitioner acts only within the scope of employment in the hospital; and (5) the hospital authorizes the practitioner to dispense or prescribe under its registration and assigns a specific internal code number for each practitioner so authorized.

As you just read, the criteria for utilizing the hospital’s DEA registration number are very specific, so be sure the hospital and the physician follow and abide by each requirement set forth.  This includes, but is not limited to, that the practitioner is employed by the hospital and that the practitioner is authorized to prescribe, dispense, or administer controlled substances within that state.