Controlled Substances Act Registrations (CSA)

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Controlled Substance Act Registration Required

Any person or business in Iowa or that will transport controlled substances into Iowa and manufactures; distributes; dispenses; prescribes; conducts instructional activities, research, or chemical analysis with; or imports or exports; controlled substances included in Schedules I through V of Iowa Code chapter 124, or that proposes to engage in such activities must obtain a Controlled Substances Act (CSA) registration, unless exempt from registration pursuant to rule 657 IAC—10.8(124). Refer to 657 IAC Chapter 10, "Controlled Substances" for more information.

Every individual practitioner or researcher who administers, prescribes, stocks, or dispenses any controlled substance must be registered in accordance with both state and federal Controlled Substances Acts. 

  • State registration is issued and regulated by the Iowa Board of Pharmacy. 
  • Federal registration is issued and regulated by the Drug Enforcement Administration (DEA). 

These registrations must be renewed periodically; check the respective certificates of registration for expiration dates. Registration certificates must be maintained at the registered location(s). 

Important! A registration is issued for each practice location. 

  • Individual practitioners or researchers who personally procure and maintain a supply of controlled substances for dispensation or administration at multiple locations must obtain a separate registration for each location. 
  • Individuals who make a change in their practice location must notify both the state and federal offices.​

Controlled Substance Act Registrants

The following licensees, businesses and organizations are required to register if procuring, stocking, prescribing, administering, or dispensing controlled substances. To be eligible for CSA registration, an individual, business or organization must hold a current, active license to practice the profession or conduct business involving controlled substances. 

Practitioners

  • Advanced Registered Nurse Practitioners (ARNP)
  • Dentists (DDS/DMD)
  • Medical Doctors (MD)
  • Optometrists (OD)
  • Osteopathic Physicians (DO)
  • Physician Assistants (PA)
  • Podiatric Physicians (DPM)
  • Psychologists with Prescriptive Authority
  • Researchers 
    • Professional license not required.
    • Research protocol(s) must be approved.
  • Veterinarians (DVM)

Businesses, Institutions, Facilities & Programs

If engaged in any activities involving controlled substances, the following are required to obtain a CSA registration.

  • Analytical Laboratories
  • Clinics 
    • Includes outpatient surgery centers; and 
    • Substances use disorder clinics.
    • Note: This does not include private offices of individual practitioners or groups of practitioners)
  • Distributors
  • Dog-Training Facilities 
    • Includes privately-owned and law enforcement K-9 training programs.
  • Emergency Medical Service Programs
  • Health Care Facilities 
    • Includes care facilities;
    • Assisted living facilities; and 
    • Group homes.
  • Hospitals 
    • Includes hospital pharmacies;
    • Jails; and 
    • Animal shelters.
  • Importer/Exporters
  • Manufacturers
  • Narcotic/Medication Assisted Treatment Programs
  • Outsourcing Facilities
  • Pharmacies
  • Religious Organizations
  • Researchers
  • Reverse Distributors
  • Teaching Institutions
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Check the Status of a CSA Registration

  1. Search by License/Registration Type
    • CSA — Individual
    • CSA — Business
  2. Enter the applicant's or licensee's name. 
    • Licensees with an existing CSAR may also be searched by registration number. 

New Applicants

If the status of your application for registration is pending approval, use the Application Status Check  feature to see what information is still needed to complete your application.

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CSA Registration Instructions

Individuals and businesses are encouraged to sign up for an online profile to renew their CSARs and access other online services.  Access to CSA registration applications and forms is available at the bottom of the page. 

Individuals and  businesses may submit applications on paper.  Paper applications must be submitted with a check or money order in the amount of the fee due. Applications submitted without proper payment may be returned to the applicant.

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CSA Registration Changes

CSA registrants and licensees must report changes of information, including but not limited to:

  • Name Change;
  • Contact Information;
  • Address; and
  • Registered Drug Schedules.

Note: Evidence of a legal name change must be submitted with the request to change a name. A  copy of the updated professional certificate of license may be accepted in lieu of copies of the legal document(s).

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Controlled Substance Inventory

Federal and state laws require all controlled substances registrants to inventory all stocks of controlled substances in the possession of the registrant on the date the registrant first engages in the manufacture, distribution, dispensing, administration, prescribing, or disposing of controlled substances. In the event the registrant commences business or practice with no controlled substances on hand, that fact shall be recorded as the initial inventory. After the initial inventory, a registrant shall take a new inventory every year. The annual inventory may be taken on any date that is within one year of the previous inventory.

A pharmacy located in Iowa that dispenses controlled substances listed in Schedule II of the Controlled Substances Act shall maintain a perpetual inventory system for each of those substances. Specific requirements for maintenance and periodic reconciliation of the perpetual inventory are found in Board rule 657 IAC--10.33(124,155A). See 657 IAC chapter 10.

All inventories shall be taken either as of opening for business or as of the close of business on the inventory date and the inventory record shall identify either “opening” or “close of business.” The person making the inventory record shall date and sign the bottom of the final page and shall initial and date the bottom of all other pages of the inventory record. The inventory record shall be maintained in written, typewritten, or electronically printed form at the registered location two years from the date of the inventory. An inventory record of substances listed in Schedule I or Schedule II of the Controlled Substances Act shall be maintained separately from an inventory of all other controlled substances.

Inventory records of controlled substances shall include the name of the substance, the strength and dosage form of the substance (e.g. 10 mg. tablet), and the quantity of the substance.  An exact count shall be recorded for all substances, unless it is a liquid in a non-incremented container which can be estimated to the nearest quarter container.

It is the responsibility of both the current owner and the prospective owner to take an inventory of all controlled substances whenever there is a change in ownership of an establishment licensed by the Board. An owner may delegate the actual taking of such inventory.

It is the responsibility of the owner to take an inventory of all controlled substances whenever there is a change in the responsible individual or the pharmacist in charge, as appropriate, of any establishment licensed by the Board.

If you need additional information regarding these procedures, please contact Terry Witkowski or contact the compliance officer assigned to your area of the state.

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Controlled Substance Disposal

Any person or business registered to handle controlled substances in Iowa shall dispose of such drugs as required by law.  The responsible person:

  1. Shall contact and utilize the services of a DEA-registered and Iowa-licensed disposal firm (reverse distributor); or
  2. May contact the assigned compliance officer for their county for assistance or direction regarding the disposal of the drugs.

Disposal of Resource Conservation and Recovery Act (RCRA) Hazardous Pharmaceutical Waste

The U.S. Environmental Protection Agency (EPA) has identified the following controlled substances to be hazardous pharmaceutical waste:

  • Chloral Hydrate
  • Diazepam Gel / Injectable
  • Fentanyl Spray
  • Phenobarbital
  • Testosterone Gel / Injectable

Exemptions to EPA-Required Disposal Regulations

To be exempt from the EPA regulations for disposal of these substances, the waste must be disposed of in a manner that is publicly established in writing as acceptable by DEA or by incineration. 

Note: To date, the DEA has not publicly established in writing any particular method of disposal that meets its non-retrievable standard. As such, hazardous pharmaceutical waste must be disposed of via incineration.

Disposal of Controlled Substances from Long-Term Care Facility Patients

Controlled substances dispensed to a resident in a long-term care facility and subsequently requiring destruction due to discontinuance of the medication, death of the resident, or other reasons necessitating destruction shall be destroyed by one of the following methods:

  1. In facilities staffed by one or more persons licensed to administer medications, controlled substances may be destroyed by a licensed healthcare professional (e.g. pharmacist, registered nurse, licensed practical nurse) in witness of one other responsible adult.  

    The professional destroying or otherwise disposing of the medication must prepare and maintain a readily-retrievable record of the destruction or other disposition, which is clearly marked to indicate the destruction or other disposition of resident medications.  At a minimum, the record shall include the following information:
    • Resident's name;
    • Name, strength, and dosage form of the substance;
    • Quantity destroyed or otherwise disposed;
    • Date the substance is destroyed or disposed; and
    • Signatures or uniquely-identifying initials or other unique identifications of the professional and the witness.
  2. Place the controlled substances in a DEA-compliant controlled substances collection receptacle located within the facility. 

    Pursuant to federal regulations, a pharmacy, which has modified its registration with the DEA to be an authorized collector, may install and manage a collection receptacle at a long-term care facility.
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CSA Registration Applications and Forms

All application fees are nonrefundable and nontransferable. Withdrawal of an application, determination of ineligibility based on prior criminal convictions, or discovery of the submission of an incorrect application type will not result in the return or refund of the fee(s) paid. 

  • Do not submit an application if you are unsure of which application type to submit.  Contact staff for more information.
  • Payments should be submitted online or by check or money order. This allows for the payment to be tracked. Do not send cash.

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