Controlled Substances Act (CSA) Registration

In Iowa, anyone who handles controlled substances—such as prescribers, clinics, pharmacies, or researchers—must have a CSA registration unless exempt by law. A valid professional license is required (except for researchers), and each location must be separately registered. Both state and federal registrations are needed, with the Iowa Board of Pharmacy managing state registration and the DEA handling federal. Registrants must maintain accurate inventory records, conduct annual inventories, and follow federal disposal rules. Application status and license lookup tools are available online.

Summary

• Code Citations
  • Iowa Code Chapter 124
  • 481 Iowa Administrative Code Chapter 551 (Registration)
  • 481 Iowa Administrative Code Chapter 553 (Controlled Substances)
• Nonrefundable Fees
  • $90 (Initial and biennial renewal fee)
  • Fee may be prorated to align with an underlying professional license, if applicable
• Additional Information
  • Separate registration is required for each separate location where stocks of controlled substances are maintained
  • For most CSA registrants, a federal DEA registration is also required

Who Must Register

You must have a CSA registration if you prescribe, store, dispense, or use controlled substances. To qualify, you must also have a current, active professional license (except for researchers).

• Individual practitioners who intend to prescribe controlled substances to patients located in Iowa (Including via telehealth encounters when the practitioner is not located in Iowa)
• Researchers (approved research protocol must be provided)
• Analytical Laboratories
• Clinics (unless an onsite practitioner takes ownership and responsibility of controlled substances used onsite)
• Wholesale Distributors, 3PLs, Manufacturers, Outsourcing Facilities
• Canine trainers/handlers and animal shelters
• Emergency Medical Service (EMS) Programs
• Care Facilities (skilled, intermediate, assisted living, group homes, etc.) that provide medication management
• Hospitals
• Correctional facilities, jails, etc.
• Importers / exporters
• Narcotic/Medication-assisted Treatment programs
• Pharmacies
• Teaching institutions

Important Information for CSA Registration - Individuals

• Complete and submit the CSA Registration online or paper application including required fee(s)
• If you will use your CSA Registration to procure and maintain stocks of controlled substances, an inspection of the registered location will be required prior to issuance of the registration
• If your practice type requires registration with the Iowa Prescription Monitoring Program, your CSA registration will be processed as “Pending PMP” and you will be notified with your assigned registration number and expiration date (though it will not be current/active yet)
• You can use the given CSA registration number and expiration date to proceed with obtaining federal DEA registration
  • If you already have a DEA registration in another jurisdiction, you may opt to modify that registration to your new Iowa practice location
• Upon issuance (or update) of your federal DEA registration, you can proceed with registering with the PMP
  • If you previously created a PMP account using a DEA number from a different state and have applied for an Iowa DEA registration number, please email the PMP Administrator with your new Iowa DEA registration number so your account can be updated to provide you with appropriate access to patient records
• Upon registration with the PMP, your CSA registration will be updated to “Current/Active” status

Important Information for CSA Registration - Businesses

• Businesses seeking an initial license with the Board (pharmacies, distributors, outsourcing facilities, etc.) may indicate on these applications that the business will be handling controlled substances and a CSA Registration will be processed with the underlying license
• Businesses seeking a CSA registration that do not have an underlying license issued by the Board (care facilities, researchers, analytical laboratories, EMS programs, etc.) must submit a CSA Business registration application

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
• 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. To date, DEA has not publicly established in writing any particular method of disposal that meets its nonretrievable standard. As such, hazardous pharmaceutical waste must be disposed of via incineration.

Reporting to the PMP

• Any CSA Registrant, except a licensed veterinarian, that directly dispenses controlled substances to patients for self-administration or dispenses or administers opioid antagonists is required to report such dispensing or administration to the Iowa Prescription Monitoring Program. 

Updating Your Registration

• CSA-Individual Registration changes
  • Notification of changes to the following must be made within 30 days via the licensing database or Board form:
    • Email address
    • Address
    • telephone number
    • Registered drug schedules authorized
    • Registered location (may require onsite inspection)
  • Name change
• CSA-Business Registration changes
  • Notification of changes to the following must be made within 30 days via the licensing database or Board form:
    • Registered drug schedules authorized
    • Responsible individual (except for WDs, 3PLs, Outsourcing Facilities)
    • Ownership
  • Notification of changes to the following must be made within 30 days via submission of an application:
    • Location (application must be submitted at least 30 days prior to the change)
    • Responsible individual (WDs, 3PLs, Outsourcing Facilities)
    • Name

Resources

• Applications
  • CSA-Individual Registration application (online - new or reactivation)
  • CSA-Individual Registration application (online - renewal)
  • CSA-Individual Application (paper - new, renewal, or change)
  • CSA-Business Application (paper - new, renewal, or change)
• Other Resources
  • Contact Us