DEA Suffixes: A Quick Reference for Pharmacists

According to 21 CFR 1306.03, a prescriber must be authorized to prescribe controlled substances in the place they are licensed to practice and must either be registered with the DEA or exempted from registration (typically reserved for officials of the U.S. Army, Navy, Marine Corps, Air Force, Space Force, Coast Guard, Public Health Service, or Bureau of Prisons). There is also an exception for prescribers working in a hospital or institutional setting who are allowed to prescribe under the registration of that hospital or institution. The most common exception PAAS National^® analysts see are for medical residents in training who work in a hospital setting but do not yet have their own DEA registration. Prescription documentation requirements for these exceptions are different from a prescriber with a DEA registration, so it is important to understand what is necessary to avoid audit troubles when PBMs flag a claim due to an NPI being billed without a known prescribing authority for a controlled substance.

Controlled substance prescriptions must contain the DEA registration number of the prescriber per 21 CFR 1306.05, but what if the prescriber has one of the above exceptions?

As per 21 CFR 1301.22:

(c) An individual practitioner who is an agent or employee of a hospital or other institution may, when acting in the normal course of business or employment, administer, dispense, or prescribe controlled substances under the registration of the hospital or other institution which is registered in lieu of being registered him/herself, provided that:

1. Such dispensing, administering or prescribing is done in the usual course of his/her professional practice;
2. Such individual practitioner is authorized or permitted to do so by the jurisdiction in which he/she is practicing;
3. The hospital or other institution by whom he/she is employed has verified that the individual practitioner is so permitted to dispense, administer, or prescribe drugs within the jurisdiction;
4. Such individual practitioner is acting only within the scope of his/her employment in the hospital or institution;
5. The hospital or other institution authorizes the individual practitioner to administer, dispense or prescribe under the hospital registration and designates a specific internal code number for each individual practitioner so authorized. The code number shall consist of numbers, letters, or a combination thereof and shall be a suffix to the institution's DEA registration number, preceded by a hyphen (e.g., APO123456-10 or APO123456-A12); and
6. A current list of internal codes and the corresponding individual practitioners is kept by the hospital or other institution and is made available at all times to other registrants and law enforcement agencies upon request for the purpose of verifying the authority of the prescribing individual practitioner.

In short, a prescriber authorized by a hospital or institution to prescribe controlled substances using the DEA registration of that hospital or institution must add, as a suffix, the internal code assigned to them by the hospital or institution. PBMs may require proof a prescriber has been authorized to issue controlled substance prescriptions under the DEA registration of the hospital or institution they work for, so being able to obtain their current list of internal codes and corresponding practitioners is key. You may need to cite the law above in order to get the hospital or institution to release those records to you.

Similarly, military and other personnel exempted from DEA registration under 21 CFR 1301.23 shall state their branch of service or agency on the prescription and their service identification number in lieu of the DEA registration number required on prescription forms. Public Health Service employees would use their Social Security number as their service identification number.

PAAS Tips:

• Ensure all elements required for a controlled substance are present on your prescriptions, including the patient’s address, prescriber’s address, and DEA registration number.
• If the prescriber is exempted from registering with the DEA, ensure that the proper documentation exists like the DEA suffix or branch of service and service identification number.
• If there is a question about whether a prescriber has a valid DEA registration, use the DEA’s CSA Registration Validation Tool.
• Be able to cite 21 CFR 1301.22 to get a copy of the hospital’s or institution’s list of current internal codes and corresponding individual practitioners, if needed.

By Trenton Thiede, PharmD, MBA, President at PAAS National^®, expert third party audit assistance, FWA/HIPAA and USP 800 compliance.

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