According to the DEA Diversion Control Division, a practitioner or mid-level practitioner must have authority to dispense controlled substances under the laws of the state where they practice as a condition of DEA registration. A separate DEA registration is required for each principal place of business or professional practice where controlled substances are dispensed.
The DEA Registration Q&A explains that a practitioner with practices in two states needs a separate DEA registration in each state, because controlled substance privileges and limits are determined by that specific state. 21 CFR 1301.12 is titled "Separate registrations for separate locations": it requires a separate registration for each principal place of business or professional practice at one general physical location where controlled substances are dispensed.
DEA Registration Q&A ยท 21 CFR 1301.12
For required DEA training, see the MATE Act training guide.
DEA's page "Medical State Licensure and/or Controlled Substance Licensure" lists these jurisdictions under the column "One License Requirement":
The same DEA page lists these jurisdictions under the column "Second CS License Requirement":
DEA: Medical State Licensure and/or Controlled Substance Licensure
DEA treats NPs and PAs as mid-level practitioners. Their authority to handle controlled substances comes from state law, so check the state board.
This is an overview, not a ranking of licensing access. Statuses retain the dates and limits of the cited lists above. Unrecorded IMLC statuses remain unknown; the PA member list identifies listed members, not current privilege availability. Neighbor counts use land/river edges, excluding open-water-only and corner-only contacts.
| State or jurisdiction | Recorded status | Border context |
|---|---|---|
| Alabama | second-CS-license flag | 0 of the 4 bordering states are listed with a second-CS-license flag: none. |
| Alaska | one-license flag | Alaska has no bordering U.S. states or District of Columbia land/river neighbors; there is no bordering-state denominator. |
| Arizona | one-license flag | 3 of the 4 bordering states are listed with a second-CS-license flag: Nevada, New Mexico, Utah. |
| Arkansas | one-license flag | 3 of the 6 bordering states are listed with a second-CS-license flag: Louisiana, Missouri, Oklahoma. |
| California | one-license flag | 1 of the 3 bordering states are listed with a second-CS-license flag: Nevada. |
| Colorado | one-license flag | 4 of the 6 bordering states are listed with a second-CS-license flag: New Mexico, Oklahoma, Utah, Wyoming. |
| Connecticut | second-CS-license flag | 2 of the 3 bordering states are listed with a second-CS-license flag: Massachusetts, Rhode Island. |
| Delaware | second-CS-license flag | 2 of the 3 bordering states are listed with a second-CS-license flag: Maryland, New Jersey. |
| District of Columbia | second-CS-license flag | 1 of the 2 bordering states are listed with a second-CS-license flag: Maryland. |
| Florida | one-license flag | 1 of the 2 bordering states are listed with a second-CS-license flag: Alabama. |
| Georgia | one-license flag | 2 of the 5 bordering states are listed with a second-CS-license flag: Alabama, South Carolina. |
| Guam | second-CS-license flag | Guam has no bordering U.S. states or District of Columbia land/river neighbors; there is no bordering-state denominator. |
| Hawaii | second-CS-license flag | Hawaii has no bordering U.S. states or District of Columbia land/river neighbors; there is no bordering-state denominator. |
| Idaho | second-CS-license flag | 3 of the 6 bordering states are listed with a second-CS-license flag: Nevada, Utah, Wyoming. |
| Illinois | second-CS-license flag | 3 of the 5 bordering states are listed with a second-CS-license flag: Indiana, Iowa, Missouri. |
| Indiana | second-CS-license flag | 2 of the 4 bordering states are listed with a second-CS-license flag: Illinois, Michigan. |
| Iowa | second-CS-license flag | 3 of the 6 bordering states are listed with a second-CS-license flag: Illinois, Missouri, South Dakota. |
| Kansas | one-license flag | 2 of the 4 bordering states are listed with a second-CS-license flag: Missouri, Oklahoma. |
| Kentucky | one-license flag | 3 of the 7 bordering states are listed with a second-CS-license flag: Illinois, Indiana, Missouri. |
| Louisiana | second-CS-license flag | 0 of the 3 bordering states are listed with a second-CS-license flag: none. |
| Maine | one-license flag | 0 of the 1 bordering states are listed with a second-CS-license flag: none. |
| Maryland | second-CS-license flag | 2 of the 5 bordering states or District of Columbia are listed with a second-CS-license flag: Delaware, District of Columbia. |
| Massachusetts | second-CS-license flag | 2 of the 5 bordering states are listed with a second-CS-license flag: Connecticut, Rhode Island. |
| Michigan | second-CS-license flag | 1 of the 3 bordering states are listed with a second-CS-license flag: Indiana. |
| Minnesota | one-license flag | 2 of the 4 bordering states are listed with a second-CS-license flag: Iowa, South Dakota. |
| Mississippi | one-license flag | 2 of the 4 bordering states are listed with a second-CS-license flag: Alabama, Louisiana. |
| Missouri | second-CS-license flag | 3 of the 8 bordering states are listed with a second-CS-license flag: Illinois, Iowa, Oklahoma. |
| Montana | one-license flag | 3 of the 4 bordering states are listed with a second-CS-license flag: Idaho, South Dakota, Wyoming. |
| Nebraska | one-license flag | 4 of the 6 bordering states are listed with a second-CS-license flag: Iowa, Missouri, South Dakota, Wyoming. |
| Nevada | second-CS-license flag | 2 of the 5 bordering states are listed with a second-CS-license flag: Idaho, Utah. |
| New Hampshire | one-license flag | 1 of the 3 bordering states are listed with a second-CS-license flag: Massachusetts. |
| New Jersey | second-CS-license flag | 1 of the 3 bordering states are listed with a second-CS-license flag: Delaware. |
| New Mexico | second-CS-license flag | 1 of the 4 bordering states are listed with a second-CS-license flag: Oklahoma. |
| New York | one-license flag | 3 of the 5 bordering states are listed with a second-CS-license flag: Connecticut, Massachusetts, New Jersey. |
| North Carolina | one-license flag | 1 of the 4 bordering states are listed with a second-CS-license flag: South Carolina. |
| North Dakota | one-license flag | 1 of the 3 bordering states are listed with a second-CS-license flag: South Dakota. |
| Ohio | one-license flag | 2 of the 5 bordering states are listed with a second-CS-license flag: Indiana, Michigan. |
| Oklahoma | second-CS-license flag | 2 of the 6 bordering states are listed with a second-CS-license flag: Missouri, New Mexico. |
| Oregon | one-license flag | 2 of the 4 bordering states are listed with a second-CS-license flag: Idaho, Nevada. |
| Pennsylvania | one-license flag | 3 of the 6 bordering states are listed with a second-CS-license flag: Delaware, Maryland, New Jersey. |
| Puerto Rico | second-CS-license flag | Puerto Rico has no bordering U.S. states or District of Columbia land/river neighbors; there is no bordering-state denominator. |
| Rhode Island | second-CS-license flag | 2 of the 2 bordering states are listed with a second-CS-license flag: Connecticut, Massachusetts. |
| South Carolina | second-CS-license flag | 0 of the 2 bordering states are listed with a second-CS-license flag: none. |
| South Dakota | second-CS-license flag | 2 of the 6 bordering states are listed with a second-CS-license flag: Iowa, Wyoming. |
| Tennessee | one-license flag | 2 of the 8 bordering states are listed with a second-CS-license flag: Alabama, Missouri. |
| Texas | one-license flag | 3 of the 4 bordering states are listed with a second-CS-license flag: Louisiana, New Mexico, Oklahoma. |
| Utah | second-CS-license flag | 3 of the 5 bordering states are listed with a second-CS-license flag: Idaho, Nevada, Wyoming. |
| Vermont | one-license flag | 1 of the 3 bordering states are listed with a second-CS-license flag: Massachusetts. |
| Virginia | one-license flag | 2 of the 6 bordering states or District of Columbia are listed with a second-CS-license flag: District of Columbia, Maryland. |
| Washington | one-license flag | 1 of the 2 bordering states are listed with a second-CS-license flag: Idaho. |
| West Virginia | one-license flag | 1 of the 5 bordering states are listed with a second-CS-license flag: Maryland. |
| Wisconsin | one-license flag | 3 of the 4 bordering states are listed with a second-CS-license flag: Illinois, Iowa, Michigan. |
| Wyoming | second-CS-license flag | 3 of the 6 bordering states are listed with a second-CS-license flag: Idaho, South Dakota, Utah. |
General information, not legal or insurance advice. Confirm details with the state board, DEA, or the carrier.
Yes, according to the DEA Registration Q&A, a practitioner with practices in two states needs a separate DEA registration in each state, because controlled substance privileges and limits are set by that state.
As a condition of DEA registration, a practitioner or mid-level practitioner must have authority to dispense controlled substances under the laws of the state where they practice.
DEA's state licensure page lists some jurisdictions under "Second CS License Requirement". Confirm the exact requirement with that state's licensing board.
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