HTML Preview Dea Letterhead Exemption page number 1.
1
Office of University Counsel
Campus Box 183, P.O. Box 173364
Denver, Colorado 80217
Phone: 303-315-6617
Fax: 303-315-4446
MEMORANDUM Confidential and Privileged
Attorney Client Communication
TO: Steve Zweck-Bronner
Managing Senior Associate University Counsel
FROM: Jennifer Watson
Research Associate Attorney
Annalissa Philbin
Senior Research Associate Attorney
DATE: November 3, 2005
Updated February 12, 2009; January 21, 2011
RE: DEA Fee Exemption and DEA Licenses for Multiple Locations
I. DEA Fee Exemption
Prior to 1994, public sector employees were exempt from DEA’s registration fee. In 1994, the
DEA, in an effort to control the misuse of fee exempt status, amended its regulations and limited
the fee exemption to government owned and operated hospitals and institutions. Individual
practitioners were no longer eligible for the fee exemption.
In 1997, the DEA assumed a major overhaul of its regulations and reinstated the exemption for
public employees. The applicable regulation is 21 C.F.R. § 1301.21 and states:
(a) The Administrator shall exempt from payment of an application fee for registration or re-
registration:
(1) Any hospital or institution which is operated by an agency of the United States [or]
of any State ….
(2) Any individual practitioner who is required to obtain an individual registration in
order to carry out his or her duties as an official of an agency of the United States
[or] any State ….
The above provision specifically exempts state employees from DEA’s registration fee. The
National DEA Registration Office confirmed in 2005 that employees of state owned and
operated institutions are exempt from the payment of registration fees. The applicable regulation
has not changed since 2005.
In order to qualify for the fee exemption, the registrant must complete the fee exemption portion
of the application, and the application must be signed by the registrant’s superior certifying “to
the status and address of the registrant and to the authority of the registrant to acquire, possess, or