Kal SaadThe DEA registration is one of the most misunderstood credentials in relief veterinary medicine. Many relief vets assume the rules work the same as they did when they were employed associates. They don't.
As an independent contractor visiting different clinics, you face a unique set of DEA regulations. Getting them wrong doesn't just risk your license — it risks federal penalties starting at $15,691 per violation.
The Basics
Every veterinarian who orders, prescribes, administers, dispenses, or wastes a controlled substance must have their own DEA registration. This is non-negotiable.
You cannot use the host clinic's DEA number. Even if the clinic's owner says it's fine, even if you've done it before, even if it seems like a bureaucratic technicality — it's a federal violation.
Registration Details
- Cost: $888 per three-year term (as of 2025)
- Application: Online at the DEA Diversion Control Division website
- Processing time: 4-6 weeks for new applications
- Renewal: Must be renewed before expiration; applications should be submitted at least 45 days in advance
- Grace period: One month after expiration to reinstate without reapplying (after that, you need a new registration)
Where to Register Your Address
This catches many relief vets off guard. You don't have a single practice address — you work at a different clinic every week. Where does your DEA registration point?
Register at your home address. The DEA allows practitioners to register at their residence. In Address Line 2, designate a specific room (e.g., "Home Office, Room 2") to limit the scope of any potential DEA inspection to that room, rather than your entire home.
Why this matters: A DEA registration gives agents the right to inspect the registered premises. By designating a specific room, you contain that right to your home office — not your kitchen, bedroom, or garage.
The Black Bag Rule
This is the rule most relief vets don't know about, and it's critical.
You cannot bring your own controlled substances into a clinic that has its own DEA registration.
The "Black Bag" exemption — which historically allowed practitioners to carry controlled substances in their medical bag — does not apply when you're working at a registered location. If the clinic has a DEA registration (and virtually all veterinary clinics do), you must use the clinic's controlled substance supply.
What this means in practice:
- You cannot carry ketamine, diazepam, butorphanol, or any other controlled substance from clinic to clinic
- You must use the host clinic's supply and document usage under the clinic's DEA protocols