A state registration on top of DEA's
Does North Carolina require its own controlled-substance registration for EMS agencies?
- Status
- No
- Detail
- North Carolina's annual controlled-substance registration with DHHS runs by enumerated applicant category — clinic, hospital, nursing home, teaching institution, researcher, analytical laboratory, distributor, manufacturer, office-based opioid treatment, dog handler — and there is no EMS agency or ambulance category among them.
Partly supported
The quote states the registration duty; the value rests on what the statute does not contain, so it is partial support. What was checked: the fee schedule in the same subsection of G.S. 90-101(a) lists every applicant category and none of them is an ambulance service, EMS agency or EMS system, and the Commission's implementing rule 10A NCAC 26E .0106(c) repeats the identical list. The whole of 10A NCAC 26E — the subchapter governing manufacturers, distributors, dispensers and researchers — contains no occurrence of 'ambulance', 'emergency medical' or 'paramedic'. G.S. 90-101(c)(6) then exempts from registration a practitioner licensed by a North Carolina licensing board, and G.S. 90-101(g) lets such practitioners possess, dispense or administer controlled substances under their board's authority, which is the route an EMS system's physician medical director travels. A traveller or agency should still confirm with the DHHS Drug Control Unit before relying on this, since it is an argument from an absent category rather than a stated exemption.
Source quotation
Every person who manufactures, distributes, dispenses, or conducts research with any controlled substance within this State or who proposes to engage in any of these activities shall annually register with the North Carolina Department of Health and Human Services, in accordance with rules adopted by the Commission, and shall pay the registration fee set by the Commission for the category to which the applicant belongs.
ncleg.gov · State statute