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  • jwgilbreath

DEA form 106 —timeliness changes

Hello all!


Big news!


It has finally happened! DEA has placed a time frame on when DEA form 106s must be sent in! Also, forms must be entered electronically (I.e., No paper copies faxed to DEA!).


So, historically these has been no stated time frame for completion of the 106. For many years there has been the written requirement of initial notification in writing within 1 business day. Then the regulation stated that you must complete a 106. The 106 in itself is not the notification (yes I know some of how May use that as your notification). DEA has had some clarifying comments in the past that if you can't get the 106 to them in 60 day days you call and clarify to them the need for more time.


Well now it's official (at least after July 24, 2023)! You must send the 106 electronically to them within 45 calendar days.


DEA originally was considering 15 days but after feedback from various groups they decided 45 days is enough time. The initial notification requirement has NOT changed.


Keep this all in mind!


Thanks!


Jay G

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