Recently, we’ve been writing about ketamine-infusion clinics, which are increasingly popping up across the country (see a list of our past coverage at the end of this post). Over the coming weeks, we’ll dive deeper into individual laws and regulations governing clinics. Today, we focus on some of the high-level requirements of the Drug Enforcement Agency (DEA) on clinics and their personnel.
Ketamine is a Schedule III controlled substance, so the Controlled Substances Act (CSA) and federal regulations require that persons who manufacture, distribute, dispense, or otherwise deal in it obtain a DEA registration. “Dispensers” of ketamine who are required to receive registrations include:
Practitioners must be specific licensed medical professionals like physicians; “Mid-level practitioners” are another defined class who can vary from state to state. In California, this would include professionals such as nurse practitioners. Mid-level practitioners are generally more restricted in what they an do than are practitioners. Hospitals/clinics Retail pharmacies Teaching institutions
In other words, not just anyone can obtain a DEA registration and dispense ketamine. But determining who needs a ketamine-related registration is not always simple. Federal registrations require separate registrations for each premises in which controlled substances are dispensed, but also provide for exceptions