Little Health Law Blog
As a healthcare and business law firm, many of our clients come to us with questions relating to the proper ordering and management of controlled substances. As such, we wanted to take this opportunity to point out a recent update to the DEA’s Practitioner’s Manual.
The Drug Enforcement Administration (DEA) recently released an updated Practitioner’s Manual on June 14, 2023. This is the first updated version of the manual since 2006. The Practitioner’s Manual provides guidance for all DEA registrants handling controlled substances—including behavioral health centers and physicians—on compliance with the Controlled Substance Act (CSA) and DEA regulations. The Practitioner’s Manual can be found here.
Some of the most significant updates include the following:
Registration Requirements
Generally, every practitioner who dispenses, which includes by definition administering and prescribing, controlled substances in schedules II through V, must be registered with DEA. To register or reregister as a practitioner, a DEA Form 224 or Form 224a, respectively, must be completed. The manual includes clarifying information about how practitioners can order, use, fill out, copy, store, cancel, and return the DEA Form 222 used to order, distribute and transfer Schedule I and II controlled substances. The manual also incorporates the optional Controlled Substance Ordering System (CSOS) as a viable alternative to the paper Form 222. Continue reading ›
Our healthcare and business law firm works with many physicians in Georgia who are facing mental health and substance abuse difficulties. Sometimes those difficulties bleed into work and can cause work and/or licensure issues. Georgia offers an incredible resource dedicated to physician recovery in a way that protects Georgia citizens and minimizes career concerns for the physician—the Georgia Professional Health Program (“PHP”). This post provides 3 Facts about the Georgia PHP. If you are experiencing or are concerned about ramifications of a potential addiction or mental health disorder, in addition to seeking medical help, we recommend contacting an experienced attorney who can assist you through this difficult process and help minimize potential licensure and career impacts. If you have questions regarding this blog post or would like to speak with counsel regarding 
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Our healthcare and business law firm often assists medical practices in responding to medical record and coding audits initiated by private and governmental payors. If a payor believes there are consistent concerns with a medical practice’s claims, the payor may place the practice under a prepayment review process. This process can be very concerning to a practice and, in some cases, can place a practice at risk of shutting down. If you have questions about an 
Our healthcare and business law firm often assists provider and medical practice clients with preparing informed consents. Many clients offer treatments in an off-label use and question whether informed consents are necessary for such use. Currently, there is no FDA requirement to get a patient’s informed consent, but it may be beneficial for your practice to implement off-label informed consents. If you have questions about patient consents or would like to discuss this blog post, you may contact our healthcare and business law firm at (404) 685-1662 (Atlanta) or (706) 722-7886 (Augusta), or by email, 
After the CDC issued its 2016 Opioid Prescribing Guideline, which focused on recommendations for primary care physicians, many physicians greatly limited prescribing opioids. This was in response to the opioid epidemic in our country which had an impact on reducing opioid abuse. However, it also may have left patients undertreated for pain given the 2016 guideline’s emphasis on not prescribing opioids. In November 2022, the CDC issued updated guidance for a broader group of clinicians. This blog series provides an overview of the more-than-60-page CDC guidance. This first blog will provide an overview of what the guidance is intended to accomplish and how it is presented. Our attorneys are experienced in advising healthcare businesses and pain management practices. If you have