How to Get DEA Registered in a New State Without Opening a Full Practice

A telemedicine provider who wants to prescribe controlled substances to patients in a new state runs into the same wall almost every time: the DEA does not treat a controlled substance registration as something that follows you across state lines. It follows a location. If your practice is licensed in Texas and you want to start seeing patients in Arizona, your existing DEA number does you no good there. You need a new one, tied to an Arizona address, before you can write a single controlled substance prescription to an Arizona patient.

This trips up a lot of growing telehealth practices, because the logic doesn’t match how the rest of the business operates. Your platform is national. Your clinicians are licensed in a dozen states. Your patients never set foot in an office. But DEA registration is still, at its core, a location-based system built for brick-and-mortar practices, and it hasn’t caught up to how telemedicine actually works.

Why DEA Registration Is Tied to a Physical Address

Under the Controlled Substances Act, a practitioner needs a separate DEA registration for each state in which they intend to prescribe controlled substances, and that registration has to correspond to an actual physical location, not just a state license number. The rule (21 C.F.R. § 1301.12) exists to give the DEA a real address on file for every registrant, since controlled substance oversight assumes there’s a place where records, inventory, and prescribing activity can be tied to a specific physical site.

There’s one narrow exception worth knowing: if you already hold an active DEA registration at a primary office within a state, you generally don’t need a second registration for a secondary office in that same state, as long as you’re only prescribing at that second location and not storing or administering controlled substances there. That exception doesn’t help you at all when the new location is in a different state entirely, which is the situation most expanding telemedicine practices actually face.

What This Means If You Don’t Have an Office in the New State

Here’s the part that catches people off guard: you don’t need a full clinical practice to satisfy this requirement. You need a legitimate, verifiable physical address where you’re authorized to receive DEA correspondence and where your registration is on file. Many telemedicine providers assume this means leasing office space they’ll rarely use, staffing it, and paying for infrastructure that has nothing to do with how they actually see patients. That’s rarely necessary.

What the DEA actually wants is a real address associated with a genuine practice presence, not an empty mailbox. This is where medical coworking and flexible clinical space arrangements have become a practical answer for telehealth companies. A provider can register at a qualified medical office address, use it for state licensing and DEA purposes, and access physical exam or consultation space on an as-needed basis if a specific patient encounter or state requirement calls for it, without carrying the overhead of a dedicated full-time office.

The Application Itself

Once you have a qualifying address, the mechanics of the registration are fairly standard. You’ll need an active, unrestricted state medical license in the new state before the DEA will process the application. From there, the process (DEA Form 224 for a new registration) currently runs an $888 registration fee for a three-year term, and most first-time applicants see a decision within four to six weeks. It’s worth building that window into your expansion timeline rather than assuming it happens overnight, particularly if you’re coordinating the new DEA registration alongside a state medical license application, which often has its own multi-week processing time.

Where the Telemedicine Flexibilities Fit In

It’s worth clearing up a common point of confusion. In December 2025, the DEA issued a fourth temporary extension of the COVID-era telemedicine prescribing flexibilities, which now run through December 31, 2026. Those flexibilities let qualifying providers prescribe certain controlled substances via telemedicine without a prior in-person evaluation. That’s a meaningful convenience for how you conduct patient encounters, but it does not touch the state-by-state DEA registration requirement described above. The two rules operate independently. You can be fully compliant with the telemedicine prescribing flexibilities and still be unable to prescribe in a new state simply because you haven’t registered a physical location there.

There’s also a longer-term proposal on the table, the DEA’s Special Registration framework for telemedicine, which was first proposed in January 2025 and would eventually create a more streamlined path for telehealth-specific registration. As of this writing it hasn’t been finalized, and the DEA’s own regulatory agenda points to a final rule being considered as late as November 2026. Until that changes, the state-by-state, address-based registration process described here remains the operative rule, and practices expanding this year should plan around it rather than wait for a simpler system that may or may not arrive on schedule.

A Practical Path Forward

If you’re adding a state to your coverage map, start with the state medical license, since the DEA won’t process your registration without it. Line up a qualifying physical address in that state early, since sourcing one shouldn’t be the bottleneck that delays your launch. And build the four-to-six week DEA review window into your rollout plan so patient onboarding doesn’t outpace your ability to legally prescribe.

For telemedicine practices adding Arizona to their footprint, Viva MedSuites provides a qualified medical address that satisfies DEA and Medicare registration requirements, along with access to real clinical space when you need it. Memberships start at $199 a month, well below the cost of a traditional lease. You can learn more at vivamedsuites.com/telemedicine-az-address/ or call 480-616-2400 to talk through what your specific registration needs look like.

John Groberg is the founder of Viva MedSuites, Arizona’s largest medical coworking community, with locations in Scottsdale and Mesa serving independent practitioners since 2017.

Viva MedSuites
Email: john@vivamedsuites.com
Website: www.vivamedsuites.com

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1910 S. Stapley Dr. Suite 120
Mesa, AZ 85204
Office: 480-616-2400

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Scottsdale, AZ 85258
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