I am employed by UW-Madison. Do I quality for a fee exemption for the federal DEA registration application?
Yes. Individuals who are UW-Madison employees, whether as clinicians or researchers or both, are exempt from both federal and state registration fees on the basis of their state employment.
I have a 0% appointment at UW-Madison. Do I qualify for the fee exemption?
No. Qualification for the fee exemption is based on employment by, not association with, the University.
What if I also receive a paycheck from UW Medical Foundation (UWMF)?
If you are a clinician employed by UW-Madison, you are eligible for the fee exemption even though you also receive a paycheck from UWMF. If you are solely employed by UWMF (e.g. midlevel providers) you are not eligible for the fee exemption.
The DEA application form requires the signature of a “Certifying Official” to verify that I am eligible for the fee exemption. Who is considered a “Certifying Official?”
The “Certifying Official” needs to be someone at the university who can verify your employment status as a State of Wisconsin employee. Please contact Central HR Operations within the School of Medicine and Public Health, Office of Human Resources, at CentralHROps@med.wisc.edufor assistance.
The form asks me to write the name of the fee-exempt institution. What should I write?
You must list “University of WI-Madison” as the fee exempt institution in the portion of the application related to the fee exemption. UWMF, UW Hospitals and Clinics (UWHC), and UW Health are not fee exempt institutions; if they are listed in this portion of the application, your application process will be delayed as the exemption will be denied.
I am employed by UW-Madison, but my primary practice is located at a non-exempt facility (e.g. Meriter). How should I fill out this poriton of the form in order to ensure that I receive the fee exemption?
Enter the address of the place at which you will have your primary practice. Although the instructions for the portion of the form concerning the fee exemption indicate that the address of the exempt institution must be listed in Section 1, it is possible that these addresses will not be the same. The DEA may inquire into the address discrepancy, so please leave plenty of time for your application to be processed.
If the DEA does inquire about the address, please contact the Office of Legal Affairs (263-7400) or Jen Rauser, Risk Management for UW Medical Foundation (504-4560), in lieu of contacting the DEA directly.
I primarily practice at UWHC but do travel to other locations around the state to practice medicine as part of my UW-Madison employment. Do I need to obtain separate registrations for each location?
That depends. Although DEA registration is location-based, individuals who have registered at their primary location (e.g. 600 Highland Avenue) may not need to register at satellite locations as long as they are not acquiring controlled substances at the additional locations. If a practitioner, when traveling to hospitals or clinics around the state, is using that hospital or clinic’s stock of controlled substances, the practitioner generally does not need to register at that location, as long as the practitioner is working under the hospital or clinic’s DEA registration.
It is important to remember that the practitioner MUST register at his/her primary practice location, and if a practitioner will not simply be using a hospital or clinic’s stock of controlled substances but would be ordering substances themselves, the practitioner must register for that location.
If I am fee exempt, why am I being asked for payment information on my DEA application? If I provided my credit card information and DEA charged my credit card, can I get a refund?
If you are asked for payment information (e.g. credit card number) when submitting your electronic application, it means you did not check the box for “certification for fee exemption.” You can go back and check this box if you have not submitted your application. If you did submit your application with your credit card information and the DEA charged it, you will not be issued a refund.
If I am already registered with the DEA as a practitioner, do I need to obtain a separate DEA registration for research?
Not necessarily. Practitioners are authorized to conduct research and instructional activities with those substances for which registration was granted (21 CFR 1301.13). However, because DEA registration is location-specific, practitioners must ensure that any substances are ordered to the same location as that for which the registration was granted, and all research with controlled substances must be carried out at the same location. If a practitioner desires to practice medicine in one location, and conduct research with the same substances in another location, a separate DEA registration is required.
A separate DEA registration is also needed if a practitioner wishes to conduct research with substances not authorized by his/her DEA registration.
Note that you may be eligible for the fee exemption for both registrations. See the first FAQ above for further information.