ADA Updated (Apr 10, 2023) FAQs on DEA Registration Requirement
On April 10th, we were informed by the ADA that an updated FAQ has been posted. Please take a moment to review all the posted questions and answers. It is important content.
Remember again, this one-time 8-hour training requirement only applies to those who prescribe from Schedules II, III, IV, and V. So, if this applies to you, please read on.
While the FAQ has a lot of content, please know that the ADA is still in direct communication with the DEA to seek additional clarification.We will send out updates as soon as we receive them.If you have questions not listed in the FAQs, please send them to firstname.lastname@example.org or to the NDA and we will work on seeking answers.
While we strongly encourage you to refer to the FAQ and we’ve called out some items that we hope answer your questions:
FAQ #3 goes over the compliance deadline. Not everyone will need to comply by the June 27, 2023 deadline: “Compliance is required by the time of your next scheduled DEA registration submission—regardless of whether it is an initial registration or a renewal registration—but not before June 27, 2023. For example, if you renew on June 26, 2023, compliance is not required until your next renewal.”
FAQ #6 goes over the course requirements, including the different acceptable ways to take these courses.
FAQ #9 is a big one on eligible training: “Does the ADA offer eligible training on safe controlled substance prescribing? See the list of courses that ADA has ready to go in its digital library. There are 8 1.0 courses and are free for members. FAQ #9 also provides for: “Also note that relevant dental school coursework counts toward the federally required training for those who are less than five years out of dental school.”
The ADA also received this clarification from the DEA: “The DEA appears to be relying on the law’s designated training organizations to make good faith determinations about what courses will satisfy the new training requirement.”
FAQ #13:ADA is one of the (many) approved training providers. To that end, NDA is recommending that members go through the ADA courses – there are 8 1-hour courses offered. We are also checking with ADA if they will be offering more courses. Be sure to retain your CE certificate.
FAQ #15 (and #9 as well) also provide that: “Before taking new courses, note that past trainings from recognized groups can be used to satisfy requirement. In other words, if you received relevant training from one of the recognized groups—prior to the enactment of this new training obligation on December 29, 2022—that training counts towards the eight-hour requirement. DEA has confirmed there is no statute of limitations for past coursework to qualify.”
Again, there is a lot of information but there is more clarity now, with this updated FAQ. If you still have questions, please contact email@example.com or firstname.lastname@example.org.Please know that ADA is hard at work on this and we will continue to reach out to the ADA and send you any new information as we receive it.