Nurse Practitioner Joan Busted: DEA's Final Word
Published Date: 7/30/2026
Notice
Summary
No summary available.
Analyzed Economic Effects
4 provisions identified: 0 benefits, 4 costs, 0 mixed.
DEA can finish cases after surrender
If you are a DEA registrant, the Drug Enforcement Administration can continue and finish an enforcement case even if you voluntarily surrendered your DEA registration (the respondent surrendered her registrations on March 20, 2025). The Agency says its jurisdiction is over the registrant (the person), not only the active registration, so a final order can still be issued.
One act of diversion can trigger revocation
The Agency states that proof of a single intentional act of diversion is sufficient to support revocation of a DEA registration (the Decision cites precedent that a single intentional diversion can justify revocation). That means one proven incident of knowingly prescribing for diversion can lead to losing your registration.
California NPs must have written supervision
Nurse practitioners in California must have a written, dated, and signed standardized procedure and a supervising physician that specifies scope, recordkeeping, evaluation methods, and periodic review in order to lawfully prescribe controlled substances. For Schedule II or III drugs the standardized procedure must include patient-specific protocols and provide a copy to a pharmacist on request.
Out‑of‑state prescribing can be unlawful
The Decision affirms that using a California license or DEA registration to prescribe controlled substances outside the state is unlawful; the respondent issued over 2,500 controlled-substance prescriptions without state authority between April 2019 and March 2024. Prescribing without proper state authority (including out-of-state prescribing) was found to be outside the usual course of professional practice and supported sanctioning.
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