08/18/2023    Paul Kesselman, DPM

Pros and Cons of Not Renewing DEA License (David Cohen, DPM)

I went through this scenario several years ago
when I discontinued trauma call, performing bone
surgery, and limiting my surgical procedures to
minor soft tissue procedure. Before you proceed
with these comments: Be sure you have alternative
meds to use for those cases where analgesics may
be required. In my experience, this has been
successful for at least the past 8 years:

Step 1: Call your state board of pharmacy to
inquire if a DEA license is required to prescribe
non controlled substances. Here in NYS, the state
board of Pharmacy informed me that a DEA
registration was not required. If your state board
of pharmacy does not require a DEA number continue
onto step 2. If your state board of pharmacy does
require a DEA number you won't have much of a
choice. I don't know of any which do.

If a pharmacy or vendor calls you for a DEA
number, especially in states where verbal
prescription orders are permitted, you will need
to explain. In those states its typical that
pharmacies simply use the DEA database to verify
your identity. They should be able to accept your
NPI or state license number. The same can be true
of your medical suppliers who may require an
active DEA number for injectables. But again, a
DEA number should not be required for local
anesthetics, steroids, injectables, etc.

Step 2: Arrange for a in network (if you are a
network provider) covering provider to whom you
can refer patients to for controlled substances.
You will need a letter from that provider
(preferably another DPM, not their PCP or another
MD/DO addressed to the carrier. Many carriers
frown on your referral being the ER. I would
refrain from doing that. That increases their
costs. Another network provider near your office
is your best option.

Step 3: Draft a letter to your insurance companies
explaining why you don't have a DEA number (e.g.
you don't perform bone surgery, etc.). Upload this
letter and the one you obtained in step 2 to the
insurance company via their provider credentialing
process.

Step 4: You will need to repeat steps 2-4 every
time you need to re credential.

Be prepared for push back from some third-party
payers. But stick to your guns, you should be fine
as long as you have fulfilled all of the above.

No carrier has discontinued my participation
following the above.

Paul Kesselman, DPM, Oceanside, NY

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