FR 2025-02339

The document from the Federal Register discusses a significant decision by the Drug Enforcement Administration (DEA) to revoke the DEA Certificate of Registration previously held by Herold Pierre-Louis, a physician assistant based in Tucson, Arizona. This decision is particularly noteworthy because it underscores the importance of state authority in handling controlled substances under federal law.

General Summary

The DEA's decision to revoke Herold Pierre-Louis's registration is rooted in the fundamental requirement that medical practitioners must have both state and federal authorization to dispense controlled substances. Pierre-Louis's state license was revoked by the Arizona Regulatory Board of Physician Assistants, which automatically disqualifies him from maintaining his DEA registration. Federal regulations stipulate that a practitioner cannot handle controlled substances if their state licensing authority revokes their license to practice. As such, because Pierre-Louis no longer holds a valid medical license in Arizona, he is unable to prescribe or manage controlled substances legally, rendering his DEA registration void.

Significant Issues or Concerns

One significant issue raised by this document is the legal language and technical jargon which might be challenging for the general public to comprehend. The text contains numerous legal citations and reference codes, such as "21 U.S.C. 824(a)(3)," which may not be easily understandable to those unfamiliar with legal statutes. Moreover, acronyms such as "OSC" (Order to Show Cause) and "P.A." (Physician Assistant) are used without an initial explanation, which might confuse some readers.

Another concern is the formal process by which decisions like revocation are made. The document details the administrative procedures, including the absence of a response from Pierre-Louis to a motion and his failure to provide evidence challenging his license revocation. This might raise questions about the accessibility and transparency of such processes for practitioners.

Impact on the Public

For the broader public, this document highlights the stringent regulatory framework governing the handling of controlled substances in the United States. It reassures the public that there are strict checks and balances in place to ensure that only qualified and authorized individuals can dispense potentially harmful medications. The revocation of a practitioner's authority to handle controlled substances serves as a protective mechanism for public health and safety.

Impact on Specific Stakeholders

For medical practitioners, particularly those dealing in controlled substances, this document serves as a cautionary tale underscoring the critical importance of maintaining good standing with state licensing authorities. Losing a state license has direct and immediate implications for one's ability to practice, both at the state and federal levels.

From the DEA's perspective, this decision reinforces the agency's role in upholding the Controlled Substances Act and ensuring compliance with state and federal laws. On the other hand, for practitioners like Pierre-Louis, the revocation is a negative outcome, affecting professional standing, income potential, and perhaps reputation in the field.

Patients who were under the care of Pierre-Louis may experience disruptions as they look to find new healthcare providers. This case underscores the interconnectedness of state and federal regulatory bodies and the repercussions of administrative actions on individual practitioners and their clientele.