How to Report Naloxone and Gabapentin When the Prescriber Does Not Have a DEA Number
With respect to reporting of naloxone where the prescriber does not have a DEA license number, the following should be noted:
Typically records submitted to the VA PMP require a dispenser/pharmacy DEA and prescriber DEA. Gabapentin is not a scheduled drug and as such may be obtained from prescribers or dispensers that do not have a DEA registration. Naloxone is a Schedule VI drug and must also be reported to the PMP. Refer to these scenarios and if you have any questions, please reference the VA PMP Dispenser Guide.
Scenario 1
Pharmacy that does not dispense controlled substances but does dispense either the Schedule VI drug naloxone and/or Virginia’s only current drug of concern, gabapentin. Clinic does not have DEA number but does have NPI number.
Guideline: Leave the dispenser/pharmacy DEA number section blank in the controlled substance report. Input the dispenser/pharmacy NPI number in the appropriate field of controlled substance report.
Scenario 2
Prescriber does not prescribe controlled substances (scheduled drugs) but does dispense either the Schedule VI drug naloxone and/or Virginia’s only current drug of concern, gabapentin.
Guideline: Leave the prescriber DEA number section blank in the controlled substance report. Input the prescriber NPI number in the appropriate field of the controlled substance report.
Scenario 3 (Currently in effect)
Prescriber is a veterinarian who does not prescribe drugs in Schedules II – V, but does prescribe either the Schedule VI drug naloxone and/or Virginia’s only current drug of concern, gabapentin. Because CMS will not issue an NPI to a veterinarian, the prescriber does not have an NPI.
Guideline: Leave the prescriber DEA registration field blank in the controlled substance report. Insert “1234567893” in the prescriber NPI field and “02” in the species code field.