Administrator Terrance C. “Terry” Cole
Drug Enforcement Administration
U.S. Department of Justice
8701 Morrissette Drive
Springfield, VA 22152

PETITION FOR RULEMAKING
Pursuant to 5 U.S.C. § 553(e) and 21 C.F.R. § 1308.43, the undersigned hereby petitions the Drug Enforcement Administration (DEA) to amend its regulations regarding the prescription of controlled substances via telemedicine and the registration requirements for multi-state practitioners.
Specifically, this petition requests that the DEA:
Permanently permit the prescription of controlled medications via telehealth platforms without a mandatory, in-person prior evaluation.
Establish a single, unified DEA registration framework that allows a practitioner with a valid DEA number to prescribe controlled substances across multiple states, provided they hold a valid medical license in each respective state.

Statement of Grounds
1. The Escalating Crisis in Mental Health Access
The United States is facing a critical shortage of mental health professionals. The number of practicing psychiatrists is steadily dropping, and fewer remaining clinics accept health insurance. This has created a severe affordability and accessibility gap for vulnerable patient populations. Restricting telehealth access disproportionately harms individuals in rural or underserved areas who cannot travel to physical clinics.
2. Arbitrary Pharmacy Restrictions Exacerbate Patient Harm
In the absence of clear, permanent federal guidelines, commercial pharmacies are increasingly implementing arbitrary restrictions. These pharmacies frequently refuse to fill valid, legal prescriptions written by out-of-state or telehealth providers. This systemic gatekeeping disrupts patient care continuity, drives up healthcare costs, and leaves patients without life-sustaining medications.
3. Modern Technology Enures Robust Patient Safety and Monitoring
The historical concerns that necessitated strict in-person visits are mitigated by modern digital health infrastructure. Providers now possess the technology to conduct comprehensive remote clinical assessments, order and review lab testing remotely, and perform random toxological screenings through distributed laboratory networks.
4. Data Supports the Safety and Expansion of Telehealth Access
Data collected during the COVID-19 Public Health Emergency demonstrated that the expansion of telemedicine did not lead to a systemic increase in the diversion or abuse of controlled substances. Instead, empirical evidence shows that telehealth access drastically improved treatment retention, reduced patient mortality, and stabilized individuals managing chronic psychiatric and neurological conditions.
5. Multi-State Regulatory Redundancy Hinders Care Delivery
The current requirement for a clinician to maintain a separate DEA registration for every single state in which they practice is an antiquated, administrative burden. It creates unnecessary financial barriers and slows the deployment of medical care during regional provider shortages. Allowing one DEA number to cover multiple state licenses simplifies administrative oversight while fully preserving state medical boards' authority over licensing.

Conclusion
The technology to safely evaluate, treat, and monitor patients remotely exists today. Maintaining rigid, pre-digital barriers fails to protect the public. Instead, it actively harms patients by restricting access to necessary medical treatment. For these reasons, the petitioner respectfully requests that the DEA initiate rulemaking to modernize these regulations.
Respectfully submitted,
Joseph DesRosier MD