HRT and DEA licensing

1. I am a new graduate in my first job as an APRN. I accepted and signed a contract for a holistic clinic, which I am currently kicking myself for. I have a question in regards to DEa licensing and HRT and weight loss prescription writing... I was told by the operations director that I don't need a dea license for writing testosterone and HCG. He states that the scripts will come from the medical director and his license. What happens for our patients is they send the vials of testosterone and HCG to the office which is then broken down and placed in individual syringes and given to the patients each week or every other week. That way the patient is following up. The medical director is not in office and will not be assessing the patient. I am in Texas if that makes a difference... I don't feel comfortable with this and I wanted to get everyone's advise, especially those with experience in APRN and controlled scripts.

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2. 

   About APRNeuroatheart

   Joined: Jan '18; Posts: 5; Likes: 1
   Specialty: 1 year(s) of experience

   9 Comments

   Comment
3. 
   Jan 13

   Someone is writing scripts but not personally assessing the patient? Giant red flag.
   
   One thing I do know, and thankfully not from personal experience: the DEA don't mess around, and they don't have any sense of humor.
4. 
   Jan 13

   Yes, I thought so too. I signed a contract and I'm trying to get out of it one week in.
5. 
   Jan 13

   My opinion - "holistic practice" is only for very experienced clinicians. It is not a good fit for a new NP to learn primary care.
   
   Getting involved with any "weight loss" schemes as a new NP seems very sketchy as well.
   
   If there were any safe and easy weight loss, we would have all discovered it by now.
   
   Good luck, and someday this will be a big joke, a laugh, and a blip on the screen.
6. 
   Jan 13

   Thanks for the advice! I really want primary care but those jobs are just hard to find these days.
7. 
   Jan 14

   HCG and testosterone injections are not just holistic, but they can also be dangerous.
8. 
   Jan 15

   I agree with the other in saying you shouldn't take this job.
   
   That being said, if you are not writing the scripts just administering the medication you don't need a DEA license. Per the DEA: "A prescription is an order for medication which is dispensed to or for an ultimate user. Aprescription is not an order for medication which is dispensed for immediate administrationto the ultimate user (for example, an order to dispense a drug to an inpatient for immediateadministration in a hospital is not a prescription)."
9. 
   Jan 16

   BostonFNP, unfortunately I'm already employed with them and I have brought it up 3 times that I'm not comfortable with it. My supervising MD is not in house and I'm sure he is reviewing charts but I'm not sure. They controlled II come to the office and the HCG is then given directly to the patient with empty syringes. The testosterone is sent to the clinic and then divided into individual syringes and given to the patient in a bag. The process is what confuses me and why I'm so unsure about continuing to be employed with them if they won't let me get my DEA.
10. 
    Jan 16

    Quote from APRNeuroatheart

    BostonFNP, unfortunately I'm already employed with them and I have brought it up 3 times that I'm not comfortable with it. My supervising MD is not in house and I'm sure he is reviewing charts but I'm not sure. They controlled II come to the office and the HCG is then given directly to the patient with empty syringes. The testosterone is sent to the clinic and then divided into individual syringes and given to the patient in a bag. The process is what confuses me and why I'm so unsure about continuing to be employed with them if they won't let me get my DEA.

    Wait, the patients are walking out of the clinic with controlled substances in a bag with no script? You are not physically injecting them?
    
    I am not exactly sure what the legality of that is, but I wouldn't risk my license on it.
11. 
    Jan 16

    Yes that is correct. The HCG is at least patient specific, with a label on it from the pharmacy. It is just mailed to us. The testosterone is just given to them in syringes in a Ziploc bag.

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