Following the remand by the DOJ Office of Information Policy concerning CUSP’s FOIA request for data on Controlled Substances Act registration reinstatements, the DEA was directed to provide any responsive records not requiring a national Form 104 search. In response to this directive, the DEA shared the attached spreadsheet showing the status of re-registration applications. However, the information provided in the spreadsheet lacks clarity regarding the reasons behind the registration “retirement.”

The lack of specificity in the spreadsheet poses challenges in understanding the circumstances leading to registration cessation. Various scenarios, such as failure to timely renew, professional leave of absence, voluntary surrender, or revocation as part of a DEA enforcement action, could contribute to this status. Consequently, it remains plausible that the DEA may reject up to 100 percent of re-registration applications from health care providers who surrendered their registrations under DEA pressure, believing that re-registration would be feasible.

Below is a table summarizing our findings based on the DEA’s spreadsheet of re-registration applications. The spreadsheet appears to include controlled substance prescribers, manufacturers, distributors, dispensers (e.g., opioid treatment programs, pharmacies, hospitals, health departments, emergency medical service providers, veterinary colleges, and animal control agencies), and disposal companies.



Total Approved 


Total w/o Approval


Percent Approved


Percent Unapproved/Undecided