The Unintended Impact Of DEA's New Registration Policy

By Larry Cote, Quarles & Brady LLP (November 18, 2016, 10:46 AM EST) -- A recently announced change in Drug Enforcement Administration policy regarding how it treats untimely renewals of a practitioner's registration could have unintended consequences that will place pharmacies and other providers at risk.

In passing the Comprehensive Drug Abuse Prevention and Control Act of 1970 and the Controlled Substances Import and Export Act (CSIEA) (21 U.S.C. 801-971), as amended (hereinafter, CSA), Congress empowered the DEA (as delegated by the attorney general) to maintain a closed system of distribution to ensure that controlled substances are readily available for the legitimate medical and scientific needs of the United States and to protect the public...

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