Numbers: DEA, NPI, Furnishing
What is a Furnishing Number? How do I get a Furnishing Number?
A Furnishing Number is the unique code given to licensed California naturopathic doctors to be used for prescribing. It is typically the doctor's license number preceded by the letters “NDF”. This number can be used to independently prescribe natural and synthetic hormones (except scheduled hormones like testosterone and hCG). A DEA number is necessary to prescribe any scheduled hormones.
The application for a furnishing number is part of the application for your ND license. In order to qualify for a furnishing number, the NMC requires that an applicant must show evidence of 48 hours of instruction in pharmacology that included the pharmacokinetic and pharmacodynamic principles and properties of the drugs to be ordered or furnished. To comply with this requirement, the instruction must have been offered by one of the following (Source: NMC Regulations Section 4212):
An approved naturopathic medical school.
An institution of higher learning that offers a baccalaureate or higher degree in medicine, nursing, pharmacy, or public health.
An educational institution or provider with standards and course content that are equivalent to the educational standards approved by State Law and by the Bureau.
Most newer NDs will have met the above requirements through their curriculum.
What is an NPI number? How do I get my NPI number?
The National Provider Identifier (NPI) is a unique 10 digit code used to identify health care providers in standard transactions, such as health care claims. NPIs may also be used to identify health care providers on prescriptions or lab orders, in coordination of benefits between health plans, in patient medical record systems, and in other ways. It was created in response to the Administrative Simplification provisions of the Health Insurance Portability and Accountability Act of 1996 (HIPAA), which mandated the adoption of a standard unique identifier for health care providers.
To apply for you NPI online, visit the National Plan & Provider Enumeration System (NPPES) Application website. They also have a helpful Application Instructions page. You will be asked for standard identifying information and will have to select your provider taxonomy (naturopath is specified after you select “other” in the initial menu). There is no fee to apply. Numbers are usually issued in 2-7 business days.
What is a DEA number? How do I get my DEA number?
A DEA number is a unique identifier used to prescribe controlled substances (otherwise known as scheduled drugs). NDs can independently prescribe natural and synthetic hormones, but need a DEA number to prescribe any scheduled hormones (i.e. testosterone, hCG, GH, etc). Naturopathic doctors are legally allowed to prescribe Schedule III –V controlled substances under the supervision of a MD or DO (for more information on Supervision, see Laws Relating to the Scope of Practice). When prescribing controlled substances, an ND must use his or her own DEA number on a controlled prescription pad - not the supervising doctor's DEA number.
To apply for a DEA number, you must have a furnishing number (NDF) issued by the NMC.
To begin the application process, visit the DEA New Registration Applicant page.
In the section for Business Activities/Schedules, apply as a "Mid-Level Practitioner" and select "Naturopathic Doctor".
Check schedules III Narcotic, III Non-Narcotic, IV & V, then check the boxes for these schedules under "Prescribe."
To prescribe scheduled drugs, you need to use a barcoded prescription pad compliant with CURES criteria.
Your DEA number must be renewed every 3 years, at a current a cost of $888 (as of 2021). You will need a separate DEA number for each state you practice in, and for each location you will be prescribing controlled substances from. You may transfer a DEA number from one state to another, and there is no fee to do this. If you are dually licensed, for example as an ND and pharmacist, you will need two DEA numbers.For more information on renewing or transferring your DEA number, visit the DEA Office of Diversion Control Registration page. You can also call the Drug Enforcement Administration Registration Unit at 1-800-882-9539.
Do I need a DEA number to prescribe hormones?
Yes, hormones that are also a controlled substance (Schedule III-V) require a DEA number. Examples of scheduled hormones are: testosterone, human growth hormone, and growth hormone. A drug furnishing number/NPI is sufficient to prescribe all other hormones.
Beyond registering with the CURES 2.0 program, is there anything else NDs need to know about compliance with CURES?
The Controlled Substance Utilization Review and Evaluation System (CURES) was certified for statewide use by the Department of Justice (DOJ) on April 2, 2018. The mandate to consult CURES prior to prescribing, ordering, administering, or furnishing a Schedule II–IV controlled substance became effective on October 2, 2018. The statement of mandatory use from the California Medical Board can be found here.
You are not required to report to CURES what you prescribe and administer to patients. More information on what "mandatory use of" and "consultation of" CURES means, how to successfully meet consultation requirements, and how to document CURES consultation in a patient's file can be found here.
Prescribers must file reports of dispensed controlled substances. California Health & Safety Code Section 11165(d) requires dispensing pharmacies, clinics, or other dispensers of Schedule II through IV controlled substances to provide specified dispensing information to the Department of Justice on a weekly basis in a format approved and accepted by the DOJ.
For NDs, with each prescription of a Schedule III, or Schedule IV controlled substance, the dispensing clinic or other dispenser shall report the following information to the Department of Justice as soon as reasonably possible, but not more than seven days after the date a controlled substance is dispensed:
(1) Full name, address, and, if available, telephone number of the ultimate user or research subject, as well as the gender, and date of birth of the ultimate user.
(2) The prescriber's category of licensure, license number, national provider identifier (NPI) number, if applicable, the federal controlled substance registration number, and the state medical license number of any prescriber using the federal controlled substance registration number of a government-exempt facility.
(3) Pharmacy prescription number, license number, NPI number, and federal controlled substance registration number.
(4) National Drug Code (NDC) number of the controlled substance dispensed.
(5) Quantity of the controlled substance dispensed.
(6) ICD-10 Code classifying the disease.
(7) Number of refills ordered.
(8) Whether the drug was dispensed as a refill of a prescription or as a first-time request.
(9) Date of origin of the prescription.
(10) Date of dispensing of the prescription.
Additionally, all CURES 2.0 users are required to renew their accounts on an annual basis. Users receive renewal notifications on the renewal date and 30 days after the user's one-year renewal date.
Full text of the Health and Safety Code Section 11165 can be downloaded here (coming soon). More compliance, reporting, and access information from the Department of Justice can be found here.
