April 04, 2023
On March 28, 2023, the U.S. Substance Abuse and Mental Health Services Administration (SAMHSA) released recommendations and the U.S. Drug Enforcement Administration (DEA) issued specific guidance on how practitioners can meet the new training requirements for DEA-registered prescribers of controlled substances.
The new law requires all prescribers of schedule II – V controlled substances to meet a one-time eight-hour training requirement on identifying, treating, and managing patients with opioid or other substance use disorders. Many California-licensed physicians may have already met the new DEA requirements because California requires similar education.
While the California Medical Association (CMA) did not support the new DEA mandate, we worked to ensure that California physicians—who are already required to complete 12 hours of one-time continuing medical education (CME) in pain management and the treatment of terminally ill and dying patients, or the treatment and management of opioid-dependent patients—can use all or some of our state-mandated CME to satisfy the DEA requirements.
The DEA guidance states that “past trainings on the treatment and management of patients with opioid or other substance use disorders can count towards a practitioner meeting this requirement.” If you received a relevant training from one of the accredited groups listed in the DEA guidance (see page 2)—even if it was completed prior to the enactment of the new law on December 29, 2022—that training can be counted toward the new DEA requirement.
For more than 20 years, California law has required all licensed physicians to complete a one-time 12-hours of CME in pain management and the treatment of terminally ill and dying patients. These courses must include the risk of addiction associated with the use of Schedule II drugs. In 2019, a new law took effect allowing physicians to also fulfill the pain management CME requirement by completing a one-time CME course of 12 credit hours on the treatment and management of opioid-dependent patients. (For more information on California’s CME requirements, see the Medical Board of California website.)
Because the California-mandated CME provides education specifically in pain management, opioid use disorders or Schedule II drug addiction risk, CMA believes that some of the California CME that physicians have completed to meet state requirements will also meet the new DEA requirements, as long as it was provided by an accredited organization listed in the DEA guidance. Physicians must determine whether their past accredited training was similar and only need to attest to having completed such education and training on the DEA registration application or renewal form.
The program takes effect on June 27, 2023. Physicians applying for a new DEA registration after June 27, must meet the training requirements upon submission of their application. For physicians who already have a DEA license, you must complete the required training or attest to having completed past training by the next time you renew your DEA license.
Physicians who are board certified in addiction medicine or addiction psychiatry are exempt from the DEA requirements, as are physicians who received similar training in medical school in the five years prior to June 27, 2023. X-Waiver training also counts. CMA recommends that physicians new to California or new physicians who have yet to complete the California mandated CME ensure that future courses they take meet both California’s 12-hour and DEA’s 8-hour requirements to avoid having to take 20 total hours of CME.
For more information, see CMA's fact sheet.