Required Training with Respect to Opioid Use Disorder (OUD) for DEA-Registered Practitioners (EO-DEA268)

Drug Enforcement Administration
Diversion Control Division
Guidance Document
Title: Required Training with Respect to Substance Use Disorders (SUD) for DEA-Registered
Practitioners
Summary: This guidance document provides information regarding a Drug Enforcement
Administration (DEA)-registered practitioner’s attestation of the training requirement in Section
1263 of the recently enacted Consolidated Appropriations Act of 2023 (CAA). This guidance will be
sent via email to all DEA-registered pharmacies and practitioners and will be posted on the DEA
guidance portal.
Activity: Attestation of Training Requirement by DEA-Registered Practitioners
To Whom It Applies: All DEA-registered practitioners that are not solely veterinarians
Background: On December 29, 2022, President Biden signed into law the CAA,1 one section of
which created an education mandate for training in the identification and management of substance
use disorders (SUDs) among practitioners, with the exception of those who are solely veterinarians,
seeking to renew or newly apply for DEA registration to prescribe controlled medications.
Section 1263(a) of the CAA2 added subsection (l) to 21 U.S.C. 823, which requires all “qualified
practitioners” to complete required training with respect to substance use disorders as a condition of
registration. Section 1263(a) defines the term “qualified practitioner” as a practitioner who (i) is
licensed under State law to prescribe controlled substances, and (ii) is not solely a veterinarian.3
This means that all DEA-registered practitioners who are not solely veterinarians must meet the
training requirement. This includes, but is not limited to, DEA-registered physicians, mid-level
practitioners, pharmacists registered as mid-level practitioners, naturopathic physicians, dentists, and
optometrists.4
DEA-registered practitioners that are not solely veterinarians must, beginning with the “first
applicable registration,” satisfy one of the applicable training requirements set forth in the CAA.
The term “first applicable registration” means the first registration or renewal of registration by a
qualified practitioner on or after June 27, 2023, under 21 U.S.C. 823(l)(4)(A).
Section 1263(a) also amended the CSA to add 21 U.S.C. 823(l)(2)(B), which requires DEA to
provide to qualified practitioners “[n]ot later than 90 days after the date of enactment . . . a single
written, electronic notification of the training described at [21 U.S.C. 823(l)(1)(A)(iv)-(v) and
(1)(B)(i)-(ii)].” DEA has provided this electronic notification, which outlines how practitioners can
satisfy the new training requirement; this letter is posted on DEA’s website.
Question: I am a DEA-registered practitioner. How do I attest that I completed the training
1 Pub. L. No. 117-328, 136 Stat. 4459 (2022).
2 Pub. L. No. 117-328, div. FF, tit. I(B), ch. 6, § 1263(a), 136 Stat. 4459, 5683-5684 (amending the CSA to add
standards for training), codified at 21 U.S.C. 823(l)(1)(A)-(B).
3 Codified at 21 U.S.C. 823(l)(4)(B).
4 21 U.S.C. 802(21).

DEA Registrant 	Page 2
requirement for SUD required by the CAA?
Answer: As a condition of registration, the new training requirement in section 1263(a) of the CAA
went into effect on June 27, 2023, and applies to all qualified practitioners when they apply for a
new registration or a renewal of registration on or after that date. DEA-registered practitioners that
are not solely veterinarians must, upon initial application or application for renewal of a registration
(beginning on June 27, 2023), attest to meeting one of three standards for training set forth in the
CAA5:
1. 	The applicant is a physician holding a board certification in addiction psychiatry or addiction
medicine from the American Board of Medical Specialties, a board certification from the
American Board of Addiction Medicine, or a board certification in addiction medicine from
the American Osteopathic Association.
2. 	The applicant is a physician who graduated in good standing from an accredited school of
allopathic medicine, osteopathic medicine, dental surgery, or dental medicine in the United
States during the past 5 years and successfully completed a comprehensive allopathic or
osteopathic medicine curriculum or accredited medical residency or dental surgery or dental
medicine curriculum that included not less than 8 hours of training on treating and managing
patients with opioid or other substance use disorders, including the appropriate clinical use
of all medications approved by the FDA for treatment of substance use disorder or the safe
pharmacological management of dental pain and screening, brief intervention, and referral
for appropriate treatment of patients with or at risk of developing opioid and other substance
use disorders.
Those applicants, other than a physician or a veterinarian, legally authorized by the State to
dispense controlled medications under schedules II-V, may meet the training requirement
when they have graduated in good standing from an accredited physician assistant school or
accredited school of advanced practice nursing in the United States during the past 5 years,
and successfully completed a comprehensive physician assistant or advanced practice
nursing curriculum that included at least 8 hours of training on treating and managing
patients with opioid or other substance use disorders, including the appropriate clinical use
of all medications approved by the FDA for the treatment of substance use disorder.
3. 	The applicant is a physician who has completed at least 8 hours of training (inclusive or
incremental) with respect to the treatment and management of patients with opioid or other
substance use disorders or the safe pharmacological management of dental pain and
screening, brief intervention, and referral for appropriate treatment of patients with or at risk
of developing opioid and other substance use disorders by an entity listed in the CAA.6
5 Pub. L. No. 117-328, § 1263(a), 136 Stat. 4459, 5683-5684 (amending the CSA to add standards for training, codified
at 21 U.S.C. 823(l)(1)(A)-(B)).
6 In accordance with the CAA, this training may be provided by the following entities: the American Society of
Addiction Medicine, the American Academy of Addiction Psychiatry, the American Medical Association, the American

DEA Registrant 	Page 3
For those applicants who are non-physicians and legally authorized by the State to dispense
controlled medications under schedules II-V, at least 8 hours of training must include
training with respect to the treatment and management of patients with opioid or other
substance use disorders delivered by an entity listed in the CAA. 7
It should be noted that this is a one-time attestation and trainings can occur in classroom settings,
seminars at professional society meetings, or virtual offerings.
DEA has modified the DEA Form 224 and DEA Form-224a applications for
registration/renewal, in order for practitioners to attest to the training standards at their first
applicable registration. The term “first applicable registration” means the first registration or
renewal of registration by a qualified practitioner on or after June 27, 2023, under 21 U.S.C.
823(l)(4)(A). The updated forms will be available from June 27, 2023, and include a section where
a practitioner will attest to meeting the required training according to one of the standards identified
above. It is recommended that each practitioner keep a record of training certificates or other
materials documenting completion. However, these documents will not need to be submitted to
DEA for review at the time of initial application or renewal of registration. After a practitioner
attests to the completion of the CAA’s training requirement, if DEA approves the new or renewal
application for registration, the new certificate of registration will be issued.
For information on how to satisfy the training requirement, please see the letter dated March 27,
2023, which DEA posted on its website. Practitioners can find additional information related to
recommended training content on SAMHSA’s website at Recommendations for Curricular Elements
in Substance Use Disorders Training | SAMHSA.
The contents of this document do not have the force and effect of law and are not meant to bind
the public in any way. This document is intended only to provide clarity to the public regarding
existing requirements under the law or Department of Justice policies.
EO-DEA268, DEA-DC-075, August 31, 2023
Osteopathic Association, the American Dental Association, the American Association of Oral and Maxillofacial
Surgeons, the American Psychiatric Association, or any other organization accredited by the Accreditation Council for
Continuing Medical Education (ACCME) or the Commission for Continuing Education Provider Recognition (CCEPR);
any organization accredited by a State medical society accreditor that is recognized by the ACCME or the CCEPR; any
organization accredited by the American Osteopathic Association to provide continuing medical education; or any
organization approved by the Assistant Secretary for Mental Health and Substance Use, the ACCME, or the CCEPR.
7 In accordance with the CAA, this training may be provided by the following entities: the American Society of
Addiction Medicine, the American Academy of Addiction Psychiatry, the American Medical Association, the American
Osteopathic Association, the American Nurses Credentialing Center, the American Psychiatric Association, the
American Association of Nurse Practitioners, the American Academy of Physician Associates, or any other organization
approved or accredited by the Assistant Secretary for Mental Health and Substance Use or the ACCME.