DEA numbers with drugs of concern

The pharmacy DEA number (PHA03) and prescriber DEA number (PRE02) are always shown as required fields in the ASAP 4.x specifications in every state’s dispenser’s guide. Many states have added non scheduled medications medications (drugs of concern) to the list of medications that need to be reported to their PDMP systems. These drugs of concern (DofC’s) include Fioricet, Gabapentin, and so forth. Pharmacies and prescribers are not required to have a DEA number to dispense or prescribe drugs of concern since they are not scheduled medications at the federal level. (DEA) This leads to issues with PDMP reporting since there may be no value for the required fields PHA03 or PRE02.

Many of the entities which don’t have a DEA number also don’t have a NPI number so that is not a solution. One option is to require the pharmacy phone number (PHA10) and prescriber phone number (PRE08) when a DEA number is not available. Depending on the ASAP version, the pharmacy license number (PHA13) and prescriber state license number (PRE04) could be used instead.

It’s unclear what happens in states which require the pre-registration of the pharmacy DEA numbers you’re going to be reporting for. And we won’t even mention zero reporting locations with no DEA # numbers. In any case, look out for DEA numbers not actually being required fields in your reporting systems until states identify what do to in these situations.