
Yes, a second state needs a second DEA registration. 21 CFR 1301.12 requires a separate registration for each principal place of practice, and its prescribe-only exception covers extra offices only in the same state. Get the state license and any state controlled substance license first; schedules come from each practice act.
Most of an optometrist's prescribing involves drugs that are not controlled substances. Short courses of pain medication are the usual exception, and an optometrist who prescribes a controlled substance needs a DEA registration; the Nebraska and South Carolina boards say so plainly. The registration follows the same rule as the license: it is tied to a state. If you prescribe controlled substances in two states, plan on two DEA registrations.
What does the federal rule say?
The DEA regulation is short. Under 21 CFR 1301.12(a), "A separate registration is required for each principal place of business or professional practice at one general physical location where controlled substances are manufactured, distributed, imported, exported, or dispensed by a person."
There is one useful exception, and it stops at the state line. Under § 1301.12(b)(3), an office used by a practitioner "who is registered at another location in the same State in which he or she practices" does not need its own registration if controlled substances are only prescribed there, not administered or dispensed, and no supplies are kept. So an optometrist who works at three offices in Ohio can usually prescribe from all three under one Ohio registration. An optometrist who works in Ohio and Indiana cannot stretch the Ohio registration across the border.
Why can't one DEA registration cover several states?
Because the exception is written for "the same State," and each registration is tied to a principal place of practice at one physical location. A second state means a second state license, in several states a state controlled substance registration, and a separate DEA registration for an address in that state.
What has to happen before the DEA application?
The order matters, because each step relies on the one before it:
- The state optometry license, with the therapeutic certification that state requires for prescribing.
- A state controlled substance license, where the state has one. Illinois requires optometrists who prescribe controlled substances to get an Illinois controlled substance license first, then a DEA registration. Delaware issues its controlled substance registration before the Delaware DEA registration. Michigan, Rhode Island, South Dakota and Utah also issue their own. See state controlled substance licenses for optometrists.
- The DEA registration for that state's practice address.
- State follow-ups after DEA. Georgia requires registration with its PDMP within 30 days of obtaining the DEA registration. Kentucky will not renew the license of an optometrist with a DEA number who has not registered with KASPER. Alaska requires PDMP registration and 2 hours of pain management and opioid education for DEA registrants. See PDMP registration and opioid CE.
Which drugs can you prescribe once you are registered?
That comes from each state's practice act, not from DEA, and it differs a lot. Examples from current statutes and rules:
- Arkansas: Schedules I and II are excluded except hydrocodone combination products, limited to a 72-hour supply with no refills.
- Delaware: hydrocodone products in Schedule II and drugs in Schedules III to V, each up to a 72-hour supply.
- Connecticut: advanced optometric care includes Schedule II to V controlled substances.
- Maine: Schedules III, IV and V.
- Michigan: no Schedule 2 drugs or oral corticosteroids.
- Montana: oral codeine, propoxyphene, hydrocodone and dihydrocodeine products.
- North Dakota: nonscheduled drugs, plus acetaminophen with 30 mg of codeine.
- Oregon: no Schedule I or II drugs or agents outside the optometric nontopical formulary.
- Rhode Island: Schedules III to V and hydrocodone, limited to a 72-hour supply.
- Washington: oral Schedule III to V drugs on the board's list; Schedule II limited to hydrocodone combination products.
- West Virginia: hydrocodone combination products limited to a 3-day supply.
- Indiana: a Controlled Substances Registration for optometrists limited to tramadol.
- Massachusetts: optometrists may prescribe only Schedule VI (prescription) drugs; controlled substances are excluded.
A prescription that is routine in one of your states can be outside scope in the other. Keep a separate formulary note for each state where you hold a registration.
How does telehealth prescribing fit in?
Prescribing controlled substances by telehealth adds federal rules that are changing on their own schedule, and Florida separately bars telehealth prescribing of Schedule II drugs except in listed settings (Fla. Stat. § 456.47(2)(c)). Few optometrists prescribe controlled substances remotely, but tele-optometry companies should check. Our sister site covers what changes for telehealth controlled substance prescribing on Jan. 1, 2027.
Where does a multi-state optometrist usually trip?
- Applying for DEA before the state license or state controlled substance license is issued. Illinois says outright that its controlled substance license comes first.
- Assuming a relief or part-time office in another state is covered. The same-state exception does not cross a state line.
- Letting the state controlled substance license lapse. Utah's renews with the main license and needs 3.5 controlled substance CE hours; Michigan's has its own fee and conditions.
- Forgetting the CE that DEA status triggers. Arizona requires DEA holders to include at least 3 hours of opioid, substance use disorder or addiction CE in their 32 renewal hours; Wyoming requires 3 of its 40 hours on controlled substance prescribing.
- Moving and leaving the old registration open. When you stop practicing in a state, that state's registration and controlled substance license need attention too.
How do we help?
Our DEA Registration service is $249 per state, and the State Controlled Substance License service is $249 per state. We sequence them after the license, prepare each application for your review and signature, and add the renewal dates and DEA-linked CE to your tracking. You keep your own DEA and state portal logins. Prices are on the pricing page; the Illinois and Michigan pages show two states with their own controlled substance license.
Common questions
- Does my DEA registration cover a second state if I only prescribe there?
- No. The prescribe-only exception in 21 CFR 1301.12(b)(3) applies only to offices in the same state where you are already registered. Practicing in another state needs a registration for that state.
- Which states require a state controlled substance license before DEA?
- Illinois requires its controlled substance license first, and Delaware issues its registration before the Delaware DEA registration. Michigan, Rhode Island, South Dakota and Utah also issue their own controlled substance licenses or registrations.
- Can optometrists prescribe Schedule II drugs?
- It depends on the state. Several allow only hydrocodone combination products with short supply limits, Michigan bars Schedule 2, Maine allows Schedules III to V, and Massachusetts excludes controlled substances entirely.
- Do I need a DEA registration to practice optometry?
- Only to prescribe or handle controlled substances. Most optometric prescribing involves drugs that are not controlled, but any controlled substance prescription needs a DEA registration for that state.
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