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Industry Drug Abuse & Compliance
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Stay tune we are working on a great experience for you.
Join our exclusive FREE webinar!
Industry Drug Abuse & Compliance
With Ali Cooper, CUBEX® Senior Director of Corporate Accounts.
Tuesday, 11/18, 2025 at 11:00 am PT | 12:00 pm MST | 1:00 pm CST | 2:00 pm EST
You spent countless hours (and money) in veterinary medical school. Graduation day comes, you receive your veterinary medical license, and it’s finally time to put that time and money into actual practice. As a licensed veterinarian you can now legally practice veterinary medicine.
When it comes the use of controlled substances in veterinary medicine; however, do you also need a DEA registration? If you work as a veterinarian in more than one facility, or in facilities across multiple states, how many DEA registrations do you need?
What is a DEA License or Registration?
While many may refer to it as a DEA “license,” the correct terminology is DEA registration. A DEA registration certificate is separate from a state medical license as well as a state-issued controlled substance license. A DEA registration is a specific number issued by the U.S. Drug Enforcement Administration (DEA) to qualified individuals and entities granting legal authority to prescribe, dispense, distribute, manufacture, import, export, reverse distribute, or conduct research with controlled substances (Schedules I-V) and/or DEA listed chemicals. Qualifying individuals and entities include licensed healthcare providers (practitioners/clinics/hospitals), pharmacies, institutions, manufacturers, narcotic treatment programs, laboratories, researchers, reverse distributors etc. DEA registrations are categorized according to the type of activity being conducted with controlled substances or DEA listed chemicals, and separate DEA registrations are required for each separate activity and registered location.
The majority of veterinarians applying for a DEA registration apply for a practitioner registration. A DEA practitioner registration is specific to the individual it is issued to, and authorizes that individual to legally prescribe, dispense, and order controlled substances at one DEA-registered location.
Who Needs a DEA Registration
Whether or not a DEA registration is necessary is a common area of confusion for veterinarians. A DEA registration is not required to practice veterinary medicine; however, without a DEA registration veterinarians are limited in the activities they can conduct with controlled substances. Specifically, a DEA registration is required for the following:
Ordering
A DEA registration is required to order and maintain a controlled substance inventory. The address used to register with the DEA is the official DEA-registered location where a registrant may order and store an inventory. DEA registrants are permitted one registered location per DEA registration. While DEA registrants may designate authorized individuals as agents to place controlled substance orders on their behalf, the authority to order is granted to DEA registrants alone. If you have a DEA practitioner registration, ordering rights belong to you, not the facility you may work at even if the name of the facility is listed on your DEA registration.
Prescribing
A DEA registration is required to prescribe controlled substances. The prescribing authority granted under a DEA practitioner registration is not delegable. The DEA regulates the prescribing of controlled substances. DEA practitioner registrants may authorize qualified individuals under them to work with their controlled substance inventory at their registered location as long as they are adhering to DEA and state supervision requirements; however, the right to prescribe that a DEA registration grants a practitioner registrant is not delegable. A DEA practitioner registration only gives the right to prescribe to the DEA practitioner it was issued to. Prescribing rights cannot be delegated to someone else.
In-House Dispensing
The practice of veterinary medicine often involves in-house dispensing of controlled substances from a registrant’s inventory for patients instead of having a prescription filled by an outside pharmacy. Many aspects of veterinary medicine are not outlined in federal regulations. In-house dispensing for patients differentiates veterinary medicine from human medicine and has led to debates about who is permitted to in-house dispense medications for patients to take home in a veterinary facility. A prescription is required to in-house dispense controlled substances from a DEA-registrant’s inventory. Like prescribing, dispensing is a DEA-regulated activity that requires a DEA registration; therefore, in-house dispensing of controlled substances for patients to take home should be conducted by an individual with a DEA registration.
What controlled substance activities can veterinarians perform without a DEA registration? In a hospital or practice setting, licensed veterinarians may legally administer controlled substances as an authorized agent working under another DEA registrant. This includes fulfilling other duties that coincide with administering such as ensuring the administration is properly logged, any waste is wasted with a witness and documented etc. Keep in mind that administration of controlled substances must always be conducted in adherence to state supervision requirements as well.
How Many DEA Registrations Do You Need?
Many veterinarians today are practicing in more than one location. Whether you provide relief services or work for a group with multiple facilities, how many DEA registrations one needs is a question that often arises. The number of DEA licenses required boils down to your controlled substance activities and the locations they are conducted.
The following list provides veterinary practice example scenarios along with the number of DEA registrations required:
- Prescribing only, working in one state: If you only prescribe controlled substances and work at multiple veterinary facilities in one state, you only need one DEA registration.
- Prescribing only, working in multiple states: If you only prescribe controlled substances and work at multiple veterinary facilities in multiple states, you need a DEA registration for each state you practice in.
- Ordering, one location: If you order and maintain a controlled substance inventory at one location only, you only need one DEA registration.
- Ordering, multiple locations: If you order and maintain a controlled substance inventory at multiple locations, you need a separate DEA registration for each location you are ordering and maintaining an inventory at. Controlled substance inventory cannot be “shared” between locations.
- Ordering, one location, patients in multiple locations: Since the passing of the Veterinary Mobility Act of 2014, veterinarians may transport and dispense controlled substances at locations other than their DEA-registered location when treating their own patients with their own controlled substance inventory during the usual course of business. This includes crossing state lines. Therefore, a veterinarian with one DEA registration ordering a controlled substance inventory to a single practice location, may legally transport controlled substances off premises for patient treatment during the usual course of business.
DEA Registration Responsibilities
You may have heard the phrase, “A DEA registration is a privilege, not a right.” Going to veterinary medical school does not entitle you to a DEA registration. The DEA gives qualified individuals the privilege of a DEA registration, and that privilege can also be taken away if not properly managed.
As a DEA registrant, you are responsible for ensuring that your required state license(s) and DEA registration are kept current and accurate. Stay current on your renewals. If you move or have an address change, make sure you update your state licenses first and then your DEA registration. As a DEA registrant with the privilege of prescribing, you are also responsible for adhering to all applicable prescribing and dispensing laws at the federal and state level where you practice as well as for ensuring the security of your prescription pads.
Ordering DEA Registrant Responsibilities
If you use your DEA registration to order controlled substance, you are personally responsible for everything that happens with the controlled substances in your inventory in the eyes of the DEA. It does not matter who paid the invoice for the controlled substances, who dispensed/administered them to treat a patient, or if an issue occurred and you were not present. As an ordering DEA registrant of record, you are responsible to provide effective controls and procedures to guard against theft and diversion of controlled substances. That is the first regulation in the list of general security requirements in Title 21, Code of Federal Regulations. Some DEA security requirements are very specific, and others are vague. At the end of the day, the DEA expects registrants maintaining an inventory to take whatever measures are necessary to protect those controlled substances from being diverted for illicit purposes.
As part of responsibilities to guard and protect a controlled substance inventory, ordering DEA Registrants are responsible for:
- Secure storage of controlled substances.
- Ensuring physical security and access controls at the registered location.
Maintaining all required records per 21 CFR 1304
Vetting and qualifying any individuals they authorize to work with their controlled substance inventory.
Proper wasting, disposal and destruction of controlled substances.
Secure storage of any DEA Form-222s and/or DEA Controlled Substance ordering System (CSOS) credentials and prescription pads.
Adhering to DEA and state reporting requirements (theft/loss reporting, prescription drug monitoring programs as applicable etc.)
Protecting Your DEA Registration
As a DEA registrant you have the privilege of ordering controlled substances, which is something a lot of companies, organizations and facilities need. Before using your DEA registration to order a controlled substance inventory, make sure you fully understand the responsibilities that come with it. Always properly vet and authorize any individuals you allow to work with your controlled substance inventory under you. Remember, as a DEA registrant you are 100% responsible for everything that happens with the controlled substances in your inventory. The DEA registrant is the legal owner of all controlled substances ordered under their DEA registration number ,regardless of who paid the invoice. As a DEA registrant you are legally responsible for protecting your inventory and cannot delegate this responsibility to anyone else.
Ensuring the protection of your controlled substances inventory is ultimately your protection professionally.
Kelley Detweiler is a DEA and controlled substance regulatory compliance specialist who provides solutions to veterinarians through her partnership with Dr. Peter Weinstein in Simple Solutions 4 Vets. She is the DEA compliance CE provider for the American Veterinary Medical Association (AVMA), the co-author of Safeguarding Controlled Substances, published by AAHA Press, and the 2024 recipient of the Illinois State Veterinary Medical Association’s President’s Award.
About CUBEX
CUBEX is an automated inventory management platform for veterinary hospitals. Combining secure smart devices with purpose-built software, CUBEX tracks every dispense in real time, supports controlled substance compliance, reduces waste and stockouts, and streamlines replenishment through connected workflows, including integrations with leading PIMS and supplier ordering platforms. The result is less manual work, better inventory control, and more time back for veterinary teams. Learn more →
You spent countless hours (and money) in veterinary medical school. Graduation day comes, you receive your veterinary medical license, and it’s finally time to put that time and money into actual practice. As a licensed veterinarian you can now legally practice veterinary medicine.
When it comes the use of controlled substances in veterinary medicine; however, do you also need a DEA registration? If you work as a veterinarian in more than one facility, or in facilities across multiple states, how many DEA registrations do you need?
What is a DEA License or Registration?
While many may refer to it as a DEA “license,” the correct terminology is DEA registration. A DEA registration certificate is separate from a state medical license as well as a state-issued controlled substance license. A DEA registration is a specific number issued by the U.S. Drug Enforcement Administration (DEA) to qualified individuals and entities granting legal authority to prescribe, dispense, distribute, manufacture, import, export, reverse distribute, or conduct research with controlled substances (Schedules I-V) and/or DEA listed chemicals. Qualifying individuals and entities include licensed healthcare providers (practitioners/clinics/hospitals), pharmacies, institutions, manufacturers, narcotic treatment programs, laboratories, researchers, reverse distributors etc. DEA registrations are categorized according to the type of activity being conducted with controlled substances or DEA listed chemicals, and separate DEA registrations are required for each separate activity and registered location.
The majority of veterinarians applying for a DEA registration apply for a practitioner registration. A DEA practitioner registration is specific to the individual it is issued to, and authorizes that individual to legally prescribe, dispense, and order controlled substances at one DEA-registered location.
Who Needs a DEA Registration
Whether or not a DEA registration is necessary is a common area of confusion for veterinarians. A DEA registration is not required to practice veterinary medicine; however, without a DEA registration veterinarians are limited in the activities they can conduct with controlled substances. Specifically, a DEA registration is required for the following:
Ordering
A DEA registration is required to order and maintain a controlled substance inventory. The address used to register with the DEA is the official DEA-registered location where a registrant may order and store an inventory. DEA registrants are permitted one registered location per DEA registration. While DEA registrants may designate authorized individuals as agents to place controlled substance orders on their behalf, the authority to order is granted to DEA registrants alone. If you have a DEA practitioner registration, ordering rights belong to you, not the facility you may work at even if the name of the facility is listed on your DEA registration.
Prescribing
A DEA registration is required to prescribe controlled substances. The prescribing authority granted under a DEA practitioner registration is not delegable. The DEA regulates the prescribing of controlled substances. DEA practitioner registrants may authorize qualified individuals under them to work with their controlled substance inventory at their registered location as long as they are adhering to DEA and state supervision requirements; however, the right to prescribe that a DEA registration grants a practitioner registrant is not delegable. A DEA practitioner registration only gives the right to prescribe to the DEA practitioner it was issued to. Prescribing rights cannot be delegated to someone else.
In-House Dispensing
The practice of veterinary medicine often involves in-house dispensing of controlled substances from a registrant’s inventory for patients instead of having a prescription filled by an outside pharmacy. Many aspects of veterinary medicine are not outlined in federal regulations. In-house dispensing for patients differentiates veterinary medicine from human medicine and has led to debates about who is permitted to in-house dispense medications for patients to take home in a veterinary facility. A prescription is required to in-house dispense controlled substances from a DEA-registrant’s inventory. Like prescribing, dispensing is a DEA-regulated activity that requires a DEA registration; therefore, in-house dispensing of controlled substances for patients to take home should be conducted by an individual with a DEA registration.
What controlled substance activities can veterinarians perform without a DEA registration? In a hospital or practice setting, licensed veterinarians may legally administer controlled substances as an authorized agent working under another DEA registrant. This includes fulfilling other duties that coincide with administering such as ensuring the administration is properly logged, any waste is wasted with a witness and documented etc. Keep in mind that administration of controlled substances must always be conducted in adherence to state supervision requirements as well.
How Many DEA Registrations Do You Need?
Many veterinarians today are practicing in more than one location. Whether you provide relief services or work for a group with multiple facilities, how many DEA registrations one needs is a question that often arises. The number of DEA licenses required boils down to your controlled substance activities and the locations they are conducted.
The following list provides veterinary practice example scenarios along with the number of DEA registrations required:
- Prescribing only, working in one state: If you only prescribe controlled substances and work at multiple veterinary facilities in one state, you only need one DEA registration.
- Prescribing only, working in multiple states: If you only prescribe controlled substances and work at multiple veterinary facilities in multiple states, you need a DEA registration for each state you practice in.
- Ordering, one location: If you order and maintain a controlled substance inventory at one location only, you only need one DEA registration.
- Ordering, multiple locations: If you order and maintain a controlled substance inventory at multiple locations, you need a separate DEA registration for each location you are ordering and maintaining an inventory at. Controlled substance inventory cannot be “shared” between locations.
- Ordering, one location, patients in multiple locations: Since the passing of the Veterinary Mobility Act of 2014, veterinarians may transport and dispense controlled substances at locations other than their DEA-registered location when treating their own patients with their own controlled substance inventory during the usual course of business. This includes crossing state lines. Therefore, a veterinarian with one DEA registration ordering a controlled substance inventory to a single practice location, may legally transport controlled substances off premises for patient treatment during the usual course of business.
DEA Registration Responsibilities
You may have heard the phrase, “A DEA registration is a privilege, not a right.” Going to veterinary medical school does not entitle you to a DEA registration. The DEA gives qualified individuals the privilege of a DEA registration, and that privilege can also be taken away if not properly managed.
As a DEA registrant, you are responsible for ensuring that your required state license(s) and DEA registration are kept current and accurate. Stay current on your renewals. If you move or have an address change, make sure you update your state licenses first and then your DEA registration. As a DEA registrant with the privilege of prescribing, you are also responsible for adhering to all applicable prescribing and dispensing laws at the federal and state level where you practice as well as for ensuring the security of your prescription pads.
Ordering DEA Registrant Responsibilities
If you use your DEA registration to order controlled substance, you are personally responsible for everything that happens with the controlled substances in your inventory in the eyes of the DEA. It does not matter who paid the invoice for the controlled substances, who dispensed/administered them to treat a patient, or if an issue occurred and you were not present. As an ordering DEA registrant of record, you are responsible to provide effective controls and procedures to guard against theft and diversion of controlled substances. That is the first regulation in the list of general security requirements in Title 21, Code of Federal Regulations. Some DEA security requirements are very specific, and others are vague. At the end of the day, the DEA expects registrants maintaining an inventory to take whatever measures are necessary to protect those controlled substances from being diverted for illicit purposes.
As part of responsibilities to guard and protect a controlled substance inventory, ordering DEA Registrants are responsible for:
- Secure storage of controlled substances.
- Ensuring physical security and access controls at the registered location.
Maintaining all required records per 21 CFR 1304
Vetting and qualifying any individuals they authorize to work with their controlled substance inventory.
Proper wasting, disposal and destruction of controlled substances.
Secure storage of any DEA Form-222s and/or DEA Controlled Substance ordering System (CSOS) credentials and prescription pads.
Adhering to DEA and state reporting requirements (theft/loss reporting, prescription drug monitoring programs as applicable etc.)
Protecting Your DEA Registration
As a DEA registrant you have the privilege of ordering controlled substances, which is something a lot of companies, organizations and facilities need. Before using your DEA registration to order a controlled substance inventory, make sure you fully understand the responsibilities that come with it. Always properly vet and authorize any individuals you allow to work with your controlled substance inventory under you. Remember, as a DEA registrant you are 100% responsible for everything that happens with the controlled substances in your inventory. The DEA registrant is the legal owner of all controlled substances ordered under their DEA registration number ,regardless of who paid the invoice. As a DEA registrant you are legally responsible for protecting your inventory and cannot delegate this responsibility to anyone else.
Ensuring the protection of your controlled substances inventory is ultimately your protection professionally.
