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What Prescribers Should Know
This article reviews what California prescribers should know about prescribing medicines in the state. Information on requirements for prescribers who dispense or administer controlled substances and other medication will be addressed in a future article. More information on prescribing and CURES is in two CDA Practice Support resources available on cda.org
What is required to prescribe in California?
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A dentist must have an active dental license to prescribe medicines. No other state registration is required. To prescribe controlled substances, however, a dentist also must be registered with the U.S. Drug Enforcement Administration (DEA).
What are the rules for obtaining a DEA registration?
A DEA registration number is site specific. Before applying for a DEA number, a dentist should ensure their address in dental board records is the same address they are using on the DEA application. If a dentist administers a controlled substance at more than one office, the dentist must obtain separate DEA registration numbers for each location (the board requires that dentists report each place of practice). Additional DEA registrations are not required if a dentist only prescribes at other office locations within California and does not administer or dispense controlled substances there.
The DEA permits an individual practitioner, such as a locum tenens dentist, to use a home address as the
principal place of business. In such cases, the location is considered a “controlled premises” and is subject to unannounced inspections and administrative warrants. Recordkeeping and security requirements remain the same.1
Practitioners may not use a P.O. box or private mailing box address for DEA registration.
Does a dentist need a DEA registration if they do not prescribe, administer or dispense controlled substances?
The law does not require it. However, dental plans may require a dentist to be registered with the DEA as part of their credentialing process. Always check with each contracted plan prior to giving up a DEA registration.
