It's time to renew two of my three narcotic prescribing licenses. For the first time in my career, I've waffled on whether the financial outlay to the US Drug Enforcement Agency (DEA) is worth it.
At $888 each, I've considered letting two licenses lapse because I only work part-time in Montana. But several friends advised me to keep a "spare" in case I transfer to a new location.
I thought about just paying the fees until I could do a little more research, but there is no mechanism for a refund unless I die within the first year of the 3-year cycle, provide incorrect credit card digits, or accidentally duplicate payments.
The renewal fee is just part of the issue.
I also received an alert about the requirement for more "narcotics prescribing education" thanks to the Medication Access and Training Expansion Act (MATE).
The requirement seems counterintuitive because opioid prescribing has decreased for the 10th consecutive year, according to the AMA Overdose Epidemic Report. The continuing rise in overdose deaths is largely due to illegitimate manufacturing of synthetic opioids.
I've written zero outpatient narcotics prescriptions in the past 6 years, and I've written very few in my 33 years of practice. My use is limited to intravenous morphine for flash pulmonary edema or refractory angina, but unless you graduated from a training program within 5 years of the June 2023 mandate or are boarded in addiction medicine, there is no way to escape the 8-hour education requirement.
The problem is that these courses are never just 8 hours in duration. After signing up for one such CME course that cost $150, I was still dying of boredom and at risk for DVT 4 days later. That's how long it took to sit through.
Instead of the 30 seconds it should have taken to review the simple instructions to deliver Narcan, there were scores of screens followed by juvenile quizlets and cartoons. All but about 2 hours out of the 4 days is now relegated to that category of "hours of my life that I can never get back." Additionally, none of that mandatory "education" will change my prescribing habits one whit.
Of course, I would always be truthful when asked to check the box on the DEA renewal application attesting to my having completed the required education. On the outside chance that you plan to check the yes box without completing the relevant courses, those found guilty of such false claims could be fined up to $250,000 and subject to "not more than four years in prison," or both. Yikes!
Larry Houck, a former DEA investigator, explained that "[t]here are lot of people who are coming up for renewal and log on but still don't know this is a requirement." Neither ignorance nor complacency is an acceptable defense.
The only good thing that came of those 4 long days of opioid education was a motivation to drive change in our current licensing and educational experience. Why not use this opportunity to reform the DEA-physician/prescriber relationship?
The educational requirements should be curtailed for those of us who do not provide outpatient narcotic prescriptions even if we use inpatient opioids. Meds with low abuse potential should be rescheduled to minimize who gets caught in the broad net of the education requirement.
We should reduce overregulation of the legitimate prescribers by lowering, instead of increasing, licensing fees. We should change to a single license number that covers every state. In this digital age, there is no legitimate excuse to prevent this from happening.
After all, the settlements from opioid manufacturers and distributors will in time total $50 billion. It seems that at least some of the responsibilities of the DEA could shift to states, cities, and towns.
My friend Siamak Karimian, MD, who provides locum services in multiple states, pays for seven active DEA licenses every 3 years. He pointed out the hypocrisy in the current regulatory system: "It's funny that you can have only one DEA or state license and work for the government in all other states or territories with no limits, including the VA, Indian healthcare systems, or prison systems."
All other prescribers require a separate DEA number for every state. Ultimately, you'd think tracking prescriptions for a single DEA number should be far simpler than tracking someone with seven.
Competent physicians not guilty of criminal overprescribing seem to be the last to be considered in nearly every healthcare endeavor these days. It would be refreshing if they would reduce our fees and prevent this waste of our time.
And while we are at it, perhaps a more fitting punishment is due for Richard Sackler and all the Purdue Pharma–affiliated family members. The Sacklers will pay out $6 billion in exchange for immunity against civil litigation. That doesn't seem like much when they are worth $11 billion.
Perhaps they should be made to take an 8-hour course on opioid prescribing, annually and in perpetuity. Let's see them complete a few quizlets and sit through screens of instruction on how to administer Naloxone. Of course, that would be a mild punishment for those who manufactured a drug that killed hundreds of thousands. But it would be a start.
https://www.medscape.com/viewarticle/dea-training-mandate-8-hours-my-life-id-back-2024a1000avg
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