DEA Registration Number Fee Waiver Interpretation and Policy as Applicable to Residents, Subspecialty Residents and Fellows

Please read this memo from Drs. Allen Daugird and Brian Goldstein regarding Drug Enforcement Agency Registration.

MEMORANDUM

TO: UNC School of Medicine Department Chairs

UNC School of Medicine Clinical and Department Associate Chairs for Administration

UNC Hospitals Vice Presidents and Associate Vice Presidents

UNC School of Medicine Faculty

UNC Physicians & Associates Directors

School of Medicine Department Credentialing Coordinators

 

FROM: Allen Daugird, MD, MBA, President, UNC Physicians & Associates

Brian Goldstein, MD, MBA, Chief Operating Officer, UNC Hospitals

DATE: May 17, 2012

RE: Drug Enforcement Agency (DEA) Registration Number Fee Waiver Interpretation and Policy as Applicable to Residents, Subspecialty Residents and Fellows

 

Fee-Exemption for LIPs

As previously announced, effective April 1, 2011, all School of Medicine (SOM) faculty and other licensed independent providers (LIPs) employed by the UNC Health Care System are required to obtain an individual DEA registration number and to discontinue use of the institutional DEA registration number for UNC Hospitals.  Eligible LIPs are exempt from paying the DEA application fee.

In response to reports that several LIPs have received letters from the DEA denying their request for exemption from the application fee, the Office of University Counsel worked with lead officials in DEA’s central office to resolve the problem. It is, and continues to be, our position that LIPs who are required to obtain a DEA registration number under this policy[1] are exempt from paying application or renewal fees. Furthermore, it remains our position that a fee-exempt DEA registration is valid regardless of the location in which the LIP provides services, so long as the LIP is acting within the scope of his or her official state duties and his or her direct compensation for such services is provided by a state agency (e.g., UNC Health Care System). The validity of this position has been confirmed with DEA’s central office.

Please continue to observe the current policy on obtaining a DEA registration number. That means when an LIP applies for a DEA number or for a renewal of his/her registration, s/he should claim exemption from the fee. In the event DEA denies the exemption request, the LIP should follow the procedures outlined in the frequently asked questions (FAQ) available on the UNC Health Care System intranet at http://intranet.unchealthcare.org/physicians/unc_physicians_newsletters/dea/DEAPolicyFAQs.pdf.

 

Policy for Residents, Subspecialty Residents and Non-ACGME Fellows

Please also note that prior announcements stated that residents, subspecialty residents and fellows would be addressed in a separate policy to be released at a later date.  This memorandum articulates such policy.

Residents and subspecialty residents who are in a training program that is accredited by the Accreditation Council for Graduate Medical Education (ACGME) or the Commission on Dental Accreditation (CODA) may continue to use the institutional DEA registration number for UNC Hospitals, modified by an appropriate suffix, when on rotation at UNC Hospitals and/or at independent physician practices. When residents and subspecialty residents are on rotation at another hospital (e.g.,Carolinas Medical Center, Central Regional, Chatham Hospital, Moses Cones, Rex Hospital, WakeMed), they should use the institutional DEA registration number of the applicable hospital, modified by an appropriate suffix.  Furthermore, residents and subspecialty residents may continue to use the institutional DEA registration number for UNC Hospitals, modified by an appropriate suffix, when moonlighting at UNC Hospitals and UNC Hospitals-affiliated facilities.  All residents and subspecialty residents must continue to submit moonlighting applications and receive approval before engaging in any moonlighting activities.  Any questions about whether a particular facility qualifies as a UNC Hospitals-affiliated facility can be addressed through this application and approval process.  Under no circumstances are residents or subspecialty residents permitted to use the institutional DEA registration number for UNC Hospitals when moonlighting externally.

Effective July 1, 2012, non-ACGME and non-CODA fellows will be subject to the policy applicable to LIPs (i.e., they must discontinue use of institutional DEA registration numbers and obtain an individual DEA registration number).  Non-ACGME and non-CODA fellows, like LIPs, will be similarly exempt from paying the DEA application fee and their fee-exempt individual DEA registration number is valid regardless of the location in which they provide services, subject to the same restrictions set forth above and in the FAQs available at _____[RMS1] .  All subspecialty residents and fellows will be required to identify their ACGME or CODA status prior to commencing services to enable determination of and adherence to the appropriate DEA registration number policy.

Thank you in advance for your time and attention to this matter.


[1] LIPs required to obtain a DEA registration number under this policy include Physicians, Advance Practice Nurses, Physician Assistants, and Clinical Pharmacist Practitioners, who are employed on a full- or part-time basis by or are an appointed agent (i.e. volunteer) of the UNC Health Care System, UNC Hospitals, UNC P&A, or UNC School of Medicine and are appointed to the Medical Staff of UNC Hospitals.


[RMS1]Need current link as above.

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