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Waiting for DEA's Next Move: Pharmacy-to-Clinic Deliveries of Patient-Specific Controlled Substances.
Confusion persists on how DEA intends to regulate and enforce pharmacies’ delivery of patient-specific medication to physicians’ offices...

Hunter DeKoninck
Aug 7, 20254 min read


DEA is Without an ALJ. What Does that Mean for Registrants?
Last week, the Drug Enforcement Administration’s (“DEA”) last remaining administrative law judge (“ALJ”) retired, leaving DEA with no ALJ...

Hunter DeKoninck
Aug 5, 20255 min read


It's (Apparently) Never Too Late Part II: DEA & Morris & Dickson Settle
In February 2024, DEA announced it entered into a settlement agreement with Morris & Dickson Co., LLC (“Morris & Dickson”), resolving the...

Hunter DeKoninck
Feb 9, 20243 min read
Brace Yourself: DEA’s Final Rule on Quotas Squeezes Inventory Levels and Signals Further Supply Restrictions
On August 31, 2023, DEA published a final rule (“Final Rule”) regarding its management of controlled substance and List 1 Chemical (“L1...

Hunter DeKoninck
Sep 5, 20238 min read


Protect Your CSOS Credentials…Or Else.
Over the last decade, the increased use of Controlled Substance Ordering System (“CSOS”) applications (i.e., platforms used to...

Hunter DeKoninck
Aug 25, 20232 min read


New DEA Form 106 Theft & Loss Reporting Deadlines and Submission Requirements
On June 22, 2023, DEA published a final rule regarding the timing with which registrants are required to report the theft or loss of...

Hunter DeKoninck
Jun 28, 20232 min read


It's (Apparently) Never Too Late: DEA’s Delayed Revocation of Morris & Dickson’s Registrations
On May 26, 2023, the Drug Enforcement Administration (DEA) published a final decision and order (the “Final Order”) affirming an...

Hunter DeKoninck
May 31, 20233 min read


DEA’s “X” Waiver Eliminated by Congress
I On December 29, 2022, the Consolidated Appropriations Act of 2023 (Public Law No. 117-328) (the “Legislation”) was signed into law,...

Hunter DeKoninck
Jan 17, 20232 min read


DEA Temporarily Removes the 'Five Percent Rule'
Through an April 13, 2020 letter to registered practitioners, the Drug Enforcement Administration (DEA) announced that, effective January...

Hunter DeKoninck
Apr 16, 20202 min read


Key Takeaways of the DEA's 2019 National Drug Threat Assessment
The US Drug Enforcement Administration (DEA) recently released its annual National Drug Threat Assessment. While highlighting challenges...

Hunter DeKoninck
Mar 5, 20202 min read
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