Health Fit Pharmacy; Decision and Order, 24348-24350 [2018-11268]
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24348
Federal Register / Vol. 83, No. 102 / Friday, May 25, 2018 / Notices
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[FR Doc. 2018–11242 Filed 5–24–18; 8:45 am]
BILLING CODE 4410–11–P
DEPARTMENT OF JUSTICE
Drug Enforcement Administration
[Docket No. 18–11]
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Health Fit Pharmacy; Decision and
Order
On November 15, 2017, the Acting
Assistant Administrator, Diversion
Control Division, Drug Enforcement
Administration (DEA), issued an Order
to Show Cause to Health Fit Pharmacy
(Respondent), of Houston, Texas. The
Show Cause Order proposed the
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Jkt 241001
revocation of Respondent’s DEA
Certificate of Registration No.
FH1729942 on the ground that he has
‘‘no state authority to handle controlled
substances.’’ Order to Show Cause, at 1
(citing 21 U.S.C. 824(a)(3)). For the same
reason, the Order also proposed the
denial of any of Respondent’s
‘‘applications for renewal or
modification of such registration and
any applications for any other DEA
registrations.’’ Id.
With respect to the Agency’s
jurisdiction, the Show Cause Order
alleged that Respondent is the holder of
Certificate of Registration No.
FH1729942, pursuant to which it is
authorized to dispense controlled
substances as a retail pharmacy in
schedules II through V, at the registered
address of 1307 Yale Street, Suite H,
Houston, Texas. Id. The Order also
alleged that this registration does not
expire until October 31, 2018. Id.
Regarding the substantive grounds for
the proceeding, the Show Cause Order
alleged that on September 15, 2017, the
Texas State Board of Pharmacy (TSBP)
‘‘suspended’’ Respondent’s Texas
pharmacy license, and Respondent is
therefore ‘‘without authority to practice
pharmacy or handle controlled
substances in the State of Texas, the
[S]tate in which [it is] registered with
the DEA.’’ Id. at 2. Based on its ‘‘lack of
authority to [dispense] controlled
substances in . . . Texas,’’ the Order
asserted that ‘‘DEA must revoke’’
Respondent’s registration. Id. (citing 21
U.S.C. 824(a)(3); 21 CFR 1301.37(b)).
The Show Cause Order notified
Respondent of (1) its right to request a
hearing on the allegations or to submit
a written statement in lieu of a hearing,
(2) the procedure for electing either
option, and (3) the consequence for
failing to elect either option. Id. (citing
21 CFR 1301.43). The Order also
notified Respondent of its right to
submit a corrective action plan. Id. at 2–
3 (citing 21 U.S.C. 824(c)(2)(C)).
On December 4, 2017, Respondent,
through counsel, filed a letter requesting
a hearing on the allegations. Letter from
Respondent’s Counsel to Hearing Clerk
(dated Nov. 30, 2017) (hereinafter,
Hearing Request). In this letter,
Respondent ‘‘objects to the cancellation
of Health Fit Pharmacy[’s DEA]
controlled substance registration’’ for
two reasons. First, Respondent states
that, ‘‘although temporar[il]y
suspended,’’ it ‘‘maintains an active
license.’’ Id. at 1. Second, Respondent
‘‘expects to prevail’’ in a ‘‘final
contested hearing regarding the
temporary suspension of this license on
the merits . . . scheduled for February,
2018.’’ Id.
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The matter was placed on the docket
of the Office of Administrative Law
Judges and assigned to Chief
Administrative Law Judge John J.
Mulrooney, II (hereinafter, CALJ). On
December 4, 2017, the CALJ ordered the
Government to file ‘‘evidence to support
the allegation that the Respondent lacks
state authority to handle controlled
substances’’ and file ‘‘any Government
motion for summary disposition’’ no
later than December 15, 2017. Order
Directing the Filing of Government
Evidence of Lack of State Authority
Allegation and Briefing Schedule, at 1–
2. The CALJ also directed Respondent to
file its response to any summary
disposition motion no later than
December 29, 2017. Id. at 2.
On December 15, 2017, the
Government filed its Motion for
Summary Disposition. In its Motion, the
Government argued that it is undisputed
that Respondent lacks authority to
handle controlled substances in Texas
because the TSBP suspended
Respondent’s Texas medical license on
September 15, 2017. Government’s
Motion for Summary Disposition
(hereinafter Government’s Motion or
Govt. Mot.) at 2–3; TSBP Temporary
Suspension Order #A–16–008–BS1
(Government Exhibit (GX) 2 to Govt.
Mot. or ‘‘Sept. 15, 2017 TSBP Order’’).
The Government also noted that, in its
Hearing Request, Respondent did not
dispute that the TSBP had suspended
Respondent’s pharmacy license. Govt.
Mot. at 3 n.1. The Government further
argued that, ‘‘[a]bsent authority by the
State of Texas to dispense controlled
substances, Respondent is not
authorized to possess a DEA registration
in that state.’’ Id. at 3. Lastly, the
Government argued that under Agency
precedent, revocation is warranted even
where a State has temporarily
suspended a practitioner’s state
authority with the possibility of future
reinstatement. Id. at 3–4 (citations
omitted). As support for its summary
disposition request, the Government
attached, inter alia, a copy of the TSBP’s
September 15, 2017 Order directing that
Respondent’s license ‘‘is hereby
temporarily suspended . . . effective
immediately and shall continue in
effect, pending a contested hearing on
disciplinary action against the
suspended license.’’ GX 2 to Govt. Mot.,
at 14.
In its responsive pleading,
Respondent did not dispute that it
‘‘maintains a[n] active suspended
license’’ in the State of Texas.
Respondent’s Dec. 29, 2017 Response to
Government’s Motion for Summary
Disposition (hereinafter, Resp. Br.), at 2.
Instead, Respondent argued that ‘‘the
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merits of the temporary suspension is
being disputed by’’ Respondent and that
the Government filed its Motion
‘‘prematurely in li[ght] of the fact that a
final order . . . has not been entered.’’
Id. at 2–3. Finally, Respondent argued
that ‘‘[t]he effect of’’ the Government’s
motion for summary disposition ‘‘is to
circumvent contested litigation
procedure.’’ Id. at 3.
After considering these pleadings, the
CALJ issued an order recommending
that I find that there was no dispute
over the fact that ‘‘Respondent lacks
state authority to handle controlled
substances in Texas.’’ Order Granting
the Government’s Motion for Summary
Disposition, and Recommended
Rulings, Findings of Fact, Conclusions
of Law, and Decision of the
Administrative Law Judge (R.D.), at 6.
As a result, the CALJ granted the
Government’s motion for summary
disposition and recommended that I
revoke Respondent’s DEA registration
and deny any pending renewal
applications. Id.
Neither party filed exceptions to the
CALJ’s Recommended Decision.
Thereafter, the record was forwarded to
my Office for Final Agency Action.
Having reviewed the record, I find that
Respondent is currently without
authority to handle controlled
substances in Texas, the State in which
it holds its registration with the Agency,
and is thus not entitled to maintain its
DEA registration. I adopt the CALJ’s
recommendation that I revoke
Respondent’s registration and deny any
pending renewal application. I make the
following factual findings.
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Findings of Fact
Respondent is the holder of DEA
Certificate of Registration No.
FH1729942, pursuant to which it is
authorized to dispense controlled
substances in schedules II through V as
a retail pharmacy. GX 1 to Govt. Mot.
On September 15, 2017, the TSBP
issued an Order temporarily suspending
Respondent’s Texas Pharmacy License
#26701 ‘‘pending a contested case
hearing on disciplinary action against
the suspended license to be held . . .
not later than . . . [90] days after the
date of this Order.’’ GX 2 to Govt. Mot.,
at 4–5.1 In its Order, the TSBP
1 The principal basis for the TSBP’s Order was the
TSBP’s finding that Respondent’s pharmacist-incharge filled prescriptions for controlled substances
such as alprazolam 2mg and carisoprodol 350mg
when he ‘‘should have known the prescriptions
. . . were invalid, i.e., not issued for a legitimate
therapeutic purpose or valid medical need and/or
prescription forgeries, due to prescription red flags
factors indicating recurrent and readily-identifiable
nontherapeutic prescribing and dispensing activity
to a reasonable pharmacist.’’ Id. at 2–3.
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specifically directed that Respondent
‘‘not operate as a pharmacy in this state
in any manner that would allow receipt,
distribution, or dispensing prescription
drugs during the period said license is
suspended.’’ Id. at 5. The TSBP also
ordered Respondent to ‘‘immediately
transfer all prescription drugs to a
secured licensed pharmacy or other
entity with the authority to legally
possess prescription drugs, not later
than September 22, 2017.’’ Id. There is
no evidence in the record establishing
that the TSBP ever lifted this
suspension.
In its Order, the TSBP also stated that
Respondent’s pharmacy license was
‘‘current through November 30, 2017.’’
Id. at 2. Neither the CALJ nor the parties
addressed the fact that the Order stated
that Respondent’s Texas pharmacy
license would expire on November 30,
2017. As a result, I have reviewed the
TSBP’s official website, and it confirms
that Respondent’s current ‘‘License
status’’ is ‘‘Expired.’’ 2 Accordingly, I
find that Respondent currently does not
possess a pharmacy license in the State
of Texas, and thus does not possess
authority to dispense controlled
substances in the State in which it is
registered with the DEA. See id. at 5.
2 See www.pharmacy.texas.gov/dbsearch/phy_
zoom.asp?id=26701&type=1. On November 9, 2017,
the TSBP issued another suspension order stating
that Respondent ‘‘agreed to the entry of this Order
continuing the suspension of pharmacy number
26701 held by Respondent for an additional period
of . . . [120] days from the date of entry of this
Order pending a contested case hearing . . . against
the suspended license’’ before ‘‘the State Office of
Administrative Hearings.’’ TSBP Temporary
Suspension Order #A–16–008–BS2 (see
www.pharmacy.texas.gov/abo/detail/282232%20%
20P26701%20%20Health%20Fit%20
Pharmacy%20%20EDTSO%20%20A160008BS2%
20%202017-11.pdf), at 1. The TSBP also repeated
its directive that ‘‘Respondent shall not operate as
a pharmacy in this state in any manner that would
allow receipt, distribution, or dispensing
prescription drugs during the period said license is
suspended.’’ Id. The TSBP website does not show
that the TSBP ever held a subsequent hearing
regarding Respondent’s suspended pharmacy
license or took any other action to lift the
suspension.
I take official notice of the TSBP’s November
2017 enforcement action and the fact that the TSBP
website currently shows that Respondent’s Texas
pharmacy license is expired. Under the
Administrative Procedure Act (APA), an agency
‘‘may take official notice of facts at any stage in a
proceeding—even in the final decision.’’ U.S. Dept.
of Justice, Attorney General’s Manual on the
Administrative Procedure Act 80 (1947) (Wm. W.
Gaunt & Sons, Inc., Reprint 1979). In accordance
with the APA and DEA’s regulations, Respondent
is ‘‘entitled on timely request to an opportunity to
show to the contrary.’’ 5 U.S.C. 556(e); see also 21
CFR 1316.59(e). To allow Respondent the
opportunity to refute the facts of which I take
official notice, Respondent may file a motion for
reconsideration within 15 calendar days of service
of this order which shall commence on the date this
order is mailed.
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Discussion
Pursuant to 21 U.S.C. 824(a)(3), the
Attorney General is authorized to
suspend or revoke a registration issued
under section 823 of the Controlled
Substances Act (CSA), ‘‘upon a finding
that the registrant . . . has had his State
license . . . suspended [or] revoked
. . . by competent State authority and is
no longer authorized by State law to
engage in the . . . dispensing of
controlled substances.’’ Also, DEA has
long held that the possession of
authority to dispense controlled
substances under the laws of the State
in which a practitioner engages in
professional practice is a fundamental
condition for obtaining and maintaining
a practitioner’s registration. See, e.g.,
James L. Hooper, 76 FR 71371 (2011),
pet. for rev. denied, 481 Fed. Appx. 826
(4th Cir. 2012); see also Frederick Marsh
Blanton, 43 FR 27616 (1978) (‘‘State
authorization to dispense or otherwise
handle controlled substances is a
prerequisite to the issuance and
maintenance of a Federal controlled
substances registration.’’).
This rule derives from the text of two
provisions of the CSA. First, Congress
defined ‘‘the term ‘practitioner’ [to]
mean[] a . . . physician . . . or other
person licensed, registered or otherwise
permitted, by . . . the jurisdiction in
which he practices . . . to distribute,
dispense, [or] administer . . . a
controlled substance in the course of
professional practice.’’ 21 U.S.C.
802(21). Second, in setting the
requirements for obtaining a
practitioner’s registration, Congress
directed that ‘‘[t]he Attorney General
shall register practitioners . . . if the
applicant is authorized to dispense . . .
controlled substances under the laws of
the State in which he practices.’’ 21
U.S.C. 823(f).
Moreover, because ‘‘the controlling
question’’ in a proceeding brought
under 21 U.S.C. 824(a)(3) is whether the
holder of a DEA registration ‘‘is
currently authorized to handle
controlled substances in the [S]tate,’’
Hooper, 76 FR at 71371 (quoting Anne
Lazar Thorn, 62 FR 12847, 12848
(1997)), the Agency has also long held
that revocation is warranted even where
a practitioner has lost his state authority
by virtue of the State’s use of summary
process and the State has yet to provide
a hearing to challenge the suspension.
Bourne Pharmacy, 72 FR 18273, 18274
(2007); Wingfield Drugs, 52 FR 27070,
27071 (1987). Thus, even assuming that
Respondent’s pharmacy license is not
expired but is still active and
suspended, it is of no consequence that
the TSBP has suspended Respondent’s
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pharmacy license and that Respondent
may prevail in a future state hearing.
What is consequential is the fact that
Respondent is not currently authorized
to dispense controlled substances in
Texas, the State in which it is
registered.3 See GX2 to Govt. Mot. (Sept.
15, 2017 TSBP Order), at 4–5.
Accordingly, Respondent is not entitled
to maintain its DEA registration.
I will therefore adopt the CALJ’s
recommendation that I revoke
Respondent’s registration and deny any
pending applications to renew its
registration. R.D. at 6. I will also deny
any pending application to modify its
registration, or any pending application
for any other DEA registration in Texas,
as requested in the Show Cause Order.
Order to Show Cause, at 1.
Order
Pursuant to the authority vested in me
by 21 U.S.C. 823(f) and 824(a), as well
as 28 CFR 0.100(b), I order that DEA
Certificate of Registration No.
FH1729942, issued to Health Fit
Pharmacy, be, and it hereby is, revoked.
I further order that any pending
application of Health Fit Pharmacy to
renew or modify the above registration,
or any pending application of Health Fit
Pharmacy for any other DEA registration
in the State of Texas, be, and it hereby
is, denied. This Order is effective
immediately.4
Dated: May 17, 2018.
Robert W. Patterson,
Acting Administrator.
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3 In its brief opposing summary disposition,
Respondent argued that the TSBP ‘‘abused it’s [sic]
discretion in granting the temporary suspension
. . . because the evidence shows that an agent of
the DEA entrapped the Pharmacy in[to] committing
a violation of the Controlled Substance[s] Act by
intentionally failing to inform the Registrant that’’
it was filling prescriptions for a practitioner who
‘‘was not authorized to issue these prescriptions.’’
Resp. Br. at 2. Respondent’s claim relates to its
challenge to the merits of the TSBP’s decision to
suspend Respondent’s Texas pharmacy license, and
I agree with the CALJ that Respondent has failed to
show why or how this claim relates to whether
Respondent is currently authorized to dispense
controlled substances in the State of Texas. See R.D.
at 3 n.1.
4 For the same reasons which led the TSBP to
suspend Respondent’s Texas pharmacy license, I
conclude that the public interest necessitates that
this Order be effective immediately. 21 CFR
1316.67.
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Employment and Training
Administration
Program Year (PY) 2018 Workforce
Innovation and Opportunity Act (WIOA)
Allotments; PY 2018 Wagner-Peyser
Act Final Allotments and PY 2018
Workforce Information Grants
Employment and Training
Administration, Labor.
ACTION: Notice.
AGENCY:
SUMMARY: This notice announces
allotments for PY 2018 for WIOA Title
I Youth, Adult and Dislocated Worker
Activities programs; final allotments for
Employment Service (ES) activities
under the Wagner-Peyser Act for PY
2018 and the allotments of Workforce
Information Grants to States for PY
2018.
WIOA allotments for states and the
state final allotments for the WagnerPeyser Act are based on formulas
defined in their respective statutes.
WIOA requires allotments for the
Outlying Areas to be competitively
awarded rather than based on a formula
determined by the Secretary of Labor
(Secretary) as occurred under the
Workforce Investment Act (WIA).
However, for PY 2018, the Consolidated
Appropriations Act, 2018 waives the
competition requirement, and the
Secretary is using the discretionary
formula rationale and methodology for
allocating PY 2018 funds for the
Outlying Areas (American Samoa,
Guam, the Commonwealth of the
Northern Mariana Islands, the Republic
of Palau, and the United States Virgin
Islands) that was published in the
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2000). WIOA specifically included the
Republic of Palau as an Outlying Area,
except during any period for which the
Secretary of Labor and the Secretary of
Education determine that a Compact of
Free Association is in effect and
contains provisions for training and
education assistance prohibiting the
assistance provided under WIOA; no
such determinations prohibiting
assistance have been made. The formula
that the Department of Labor
(Department) used for PY 2018 is the
same formula used in PY 2017 and is
described in the section on Youth
Activities program allotments. The
Department invites comments only on
the formula used to allot funds to the
Outlying Areas.
DATES: The Department must receive
comments on the formula used to allot
funds to the Outlying Areas by June 25,
2018.
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Submit written comments
to the Employment and Training
Administration (ETA), Office of
Financial Administration, 200
Constitution Avenue NW, Room
N–4702, Washington, DC 20210,
Attention: Ms. Anita Harvey, email:
harvey.anita@dol.gov.
Commenters are advised that mail
delivery in the Washington area may be
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above.
Please submit your comments by only
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receives after the comment period has
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Comments: The Department will
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will release them upon request via email
to any member of the public. The
Department also will make all the
comments it receives available for
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during normal business hours at the
above address. If you need assistance to
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Department will make copies of this
notice available, upon request, in large
print, Braille, and electronic file. The
Department also will consider providing
the notice in other formats upon
request. To schedule an appointment to
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cautions commenters not to include
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FOR FURTHER INFORMATION CONTACT:
WIOA Youth Activities allotments—
Evan Rosenberg at (202) 693–3593 or
LaSharn Youngblood at (202) 693–3606;
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Activities and ES final allotments—
Robert Kight at (202) 693–3937;
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ADDRESSES:
DEPARTMENT OF LABOR
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Agencies
[Federal Register Volume 83, Number 102 (Friday, May 25, 2018)]
[Notices]
[Pages 24348-24350]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-11268]
-----------------------------------------------------------------------
DEPARTMENT OF JUSTICE
Drug Enforcement Administration
[Docket No. 18-11]
Health Fit Pharmacy; Decision and Order
On November 15, 2017, the Acting Assistant Administrator, Diversion
Control Division, Drug Enforcement Administration (DEA), issued an
Order to Show Cause to Health Fit Pharmacy (Respondent), of Houston,
Texas. The Show Cause Order proposed the revocation of Respondent's DEA
Certificate of Registration No. FH1729942 on the ground that he has
``no state authority to handle controlled substances.'' Order to Show
Cause, at 1 (citing 21 U.S.C. 824(a)(3)). For the same reason, the
Order also proposed the denial of any of Respondent's ``applications
for renewal or modification of such registration and any applications
for any other DEA registrations.'' Id.
With respect to the Agency's jurisdiction, the Show Cause Order
alleged that Respondent is the holder of Certificate of Registration
No. FH1729942, pursuant to which it is authorized to dispense
controlled substances as a retail pharmacy in schedules II through V,
at the registered address of 1307 Yale Street, Suite H, Houston, Texas.
Id. The Order also alleged that this registration does not expire until
October 31, 2018. Id.
Regarding the substantive grounds for the proceeding, the Show
Cause Order alleged that on September 15, 2017, the Texas State Board
of Pharmacy (TSBP) ``suspended'' Respondent's Texas pharmacy license,
and Respondent is therefore ``without authority to practice pharmacy or
handle controlled substances in the State of Texas, the [S]tate in
which [it is] registered with the DEA.'' Id. at 2. Based on its ``lack
of authority to [dispense] controlled substances in . . . Texas,'' the
Order asserted that ``DEA must revoke'' Respondent's registration. Id.
(citing 21 U.S.C. 824(a)(3); 21 CFR 1301.37(b)).
The Show Cause Order notified Respondent of (1) its right to
request a hearing on the allegations or to submit a written statement
in lieu of a hearing, (2) the procedure for electing either option, and
(3) the consequence for failing to elect either option. Id. (citing 21
CFR 1301.43). The Order also notified Respondent of its right to submit
a corrective action plan. Id. at 2-3 (citing 21 U.S.C. 824(c)(2)(C)).
On December 4, 2017, Respondent, through counsel, filed a letter
requesting a hearing on the allegations. Letter from Respondent's
Counsel to Hearing Clerk (dated Nov. 30, 2017) (hereinafter, Hearing
Request). In this letter, Respondent ``objects to the cancellation of
Health Fit Pharmacy['s DEA] controlled substance registration'' for two
reasons. First, Respondent states that, ``although temporar[il]y
suspended,'' it ``maintains an active license.'' Id. at 1. Second,
Respondent ``expects to prevail'' in a ``final contested hearing
regarding the temporary suspension of this license on the merits . . .
scheduled for February, 2018.'' Id.
The matter was placed on the docket of the Office of Administrative
Law Judges and assigned to Chief Administrative Law Judge John J.
Mulrooney, II (hereinafter, CALJ). On December 4, 2017, the CALJ
ordered the Government to file ``evidence to support the allegation
that the Respondent lacks state authority to handle controlled
substances'' and file ``any Government motion for summary disposition''
no later than December 15, 2017. Order Directing the Filing of
Government Evidence of Lack of State Authority Allegation and Briefing
Schedule, at 1-2. The CALJ also directed Respondent to file its
response to any summary disposition motion no later than December 29,
2017. Id. at 2.
On December 15, 2017, the Government filed its Motion for Summary
Disposition. In its Motion, the Government argued that it is undisputed
that Respondent lacks authority to handle controlled substances in
Texas because the TSBP suspended Respondent's Texas medical license on
September 15, 2017. Government's Motion for Summary Disposition
(hereinafter Government's Motion or Govt. Mot.) at 2-3; TSBP Temporary
Suspension Order #A-16-008-BS1 (Government Exhibit (GX) 2 to Govt. Mot.
or ``Sept. 15, 2017 TSBP Order''). The Government also noted that, in
its Hearing Request, Respondent did not dispute that the TSBP had
suspended Respondent's pharmacy license. Govt. Mot. at 3 n.1. The
Government further argued that, ``[a]bsent authority by the State of
Texas to dispense controlled substances, Respondent is not authorized
to possess a DEA registration in that state.'' Id. at 3. Lastly, the
Government argued that under Agency precedent, revocation is warranted
even where a State has temporarily suspended a practitioner's state
authority with the possibility of future reinstatement. Id. at 3-4
(citations omitted). As support for its summary disposition request,
the Government attached, inter alia, a copy of the TSBP's September 15,
2017 Order directing that Respondent's license ``is hereby temporarily
suspended . . . effective immediately and shall continue in effect,
pending a contested hearing on disciplinary action against the
suspended license.'' GX 2 to Govt. Mot., at 14.
In its responsive pleading, Respondent did not dispute that it
``maintains a[n] active suspended license'' in the State of Texas.
Respondent's Dec. 29, 2017 Response to Government's Motion for Summary
Disposition (hereinafter, Resp. Br.), at 2. Instead, Respondent argued
that ``the
[[Page 24349]]
merits of the temporary suspension is being disputed by'' Respondent
and that the Government filed its Motion ``prematurely in li[ght] of
the fact that a final order . . . has not been entered.'' Id. at 2-3.
Finally, Respondent argued that ``[t]he effect of'' the Government's
motion for summary disposition ``is to circumvent contested litigation
procedure.'' Id. at 3.
After considering these pleadings, the CALJ issued an order
recommending that I find that there was no dispute over the fact that
``Respondent lacks state authority to handle controlled substances in
Texas.'' Order Granting the Government's Motion for Summary
Disposition, and Recommended Rulings, Findings of Fact, Conclusions of
Law, and Decision of the Administrative Law Judge (R.D.), at 6. As a
result, the CALJ granted the Government's motion for summary
disposition and recommended that I revoke Respondent's DEA registration
and deny any pending renewal applications. Id.
Neither party filed exceptions to the CALJ's Recommended Decision.
Thereafter, the record was forwarded to my Office for Final Agency
Action. Having reviewed the record, I find that Respondent is currently
without authority to handle controlled substances in Texas, the State
in which it holds its registration with the Agency, and is thus not
entitled to maintain its DEA registration. I adopt the CALJ's
recommendation that I revoke Respondent's registration and deny any
pending renewal application. I make the following factual findings.
Findings of Fact
Respondent is the holder of DEA Certificate of Registration No.
FH1729942, pursuant to which it is authorized to dispense controlled
substances in schedules II through V as a retail pharmacy. GX 1 to
Govt. Mot. On September 15, 2017, the TSBP issued an Order temporarily
suspending Respondent's Texas Pharmacy License #26701 ``pending a
contested case hearing on disciplinary action against the suspended
license to be held . . . not later than . . . [90] days after the date
of this Order.'' GX 2 to Govt. Mot., at 4-5.\1\ In its Order, the TSBP
specifically directed that Respondent ``not operate as a pharmacy in
this state in any manner that would allow receipt, distribution, or
dispensing prescription drugs during the period said license is
suspended.'' Id. at 5. The TSBP also ordered Respondent to
``immediately transfer all prescription drugs to a secured licensed
pharmacy or other entity with the authority to legally possess
prescription drugs, not later than September 22, 2017.'' Id. There is
no evidence in the record establishing that the TSBP ever lifted this
suspension.
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\1\ The principal basis for the TSBP's Order was the TSBP's
finding that Respondent's pharmacist-in-charge filled prescriptions
for controlled substances such as alprazolam 2mg and carisoprodol
350mg when he ``should have known the prescriptions . . . were
invalid, i.e., not issued for a legitimate therapeutic purpose or
valid medical need and/or prescription forgeries, due to
prescription red flags factors indicating recurrent and readily-
identifiable nontherapeutic prescribing and dispensing activity to a
reasonable pharmacist.'' Id. at 2-3.
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In its Order, the TSBP also stated that Respondent's pharmacy
license was ``current through November 30, 2017.'' Id. at 2. Neither
the CALJ nor the parties addressed the fact that the Order stated that
Respondent's Texas pharmacy license would expire on November 30, 2017.
As a result, I have reviewed the TSBP's official website, and it
confirms that Respondent's current ``License status'' is ``Expired.''
\2\ Accordingly, I find that Respondent currently does not possess a
pharmacy license in the State of Texas, and thus does not possess
authority to dispense controlled substances in the State in which it is
registered with the DEA. See id. at 5.
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\2\ See www.pharmacy.texas.gov/dbsearch/phy_zoom.asp?id=26701&type=1. On November 9, 2017, the TSBP issued
another suspension order stating that Respondent ``agreed to the
entry of this Order continuing the suspension of pharmacy number
26701 held by Respondent for an additional period of . . . [120]
days from the date of entry of this Order pending a contested case
hearing . . . against the suspended license'' before ``the State
Office of Administrative Hearings.'' TSBP Temporary Suspension Order
#A-16-008-BS2 (see www.pharmacy.texas.gov/abo/detail/282232%20%20P26701%20%20Health%20Fit%20Pharmacy%20%20EDTSO%20%20A160008BS2%20%202017-11.pdf), at 1. The TSBP also repeated its directive
that ``Respondent shall not operate as a pharmacy in this state in
any manner that would allow receipt, distribution, or dispensing
prescription drugs during the period said license is suspended.''
Id. The TSBP website does not show that the TSBP ever held a
subsequent hearing regarding Respondent's suspended pharmacy license
or took any other action to lift the suspension.
I take official notice of the TSBP's November 2017 enforcement
action and the fact that the TSBP website currently shows that
Respondent's Texas pharmacy license is expired. Under the
Administrative Procedure Act (APA), an agency ``may take official
notice of facts at any stage in a proceeding--even in the final
decision.'' U.S. Dept. of Justice, Attorney General's Manual on the
Administrative Procedure Act 80 (1947) (Wm. W. Gaunt & Sons, Inc.,
Reprint 1979). In accordance with the APA and DEA's regulations,
Respondent is ``entitled on timely request to an opportunity to show
to the contrary.'' 5 U.S.C. 556(e); see also 21 CFR 1316.59(e). To
allow Respondent the opportunity to refute the facts of which I take
official notice, Respondent may file a motion for reconsideration
within 15 calendar days of service of this order which shall
commence on the date this order is mailed.
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Discussion
Pursuant to 21 U.S.C. 824(a)(3), the Attorney General is authorized
to suspend or revoke a registration issued under section 823 of the
Controlled Substances Act (CSA), ``upon a finding that the registrant .
. . has had his State license . . . suspended [or] revoked . . . by
competent State authority and is no longer authorized by State law to
engage in the . . . dispensing of controlled substances.'' Also, DEA
has long held that the possession of authority to dispense controlled
substances under the laws of the State in which a practitioner engages
in professional practice is a fundamental condition for obtaining and
maintaining a practitioner's registration. See, e.g., James L. Hooper,
76 FR 71371 (2011), pet. for rev. denied, 481 Fed. Appx. 826 (4th Cir.
2012); see also Frederick Marsh Blanton, 43 FR 27616 (1978) (``State
authorization to dispense or otherwise handle controlled substances is
a prerequisite to the issuance and maintenance of a Federal controlled
substances registration.'').
This rule derives from the text of two provisions of the CSA.
First, Congress defined ``the term `practitioner' [to] mean[] a . . .
physician . . . or other person licensed, registered or otherwise
permitted, by . . . the jurisdiction in which he practices . . . to
distribute, dispense, [or] administer . . . a controlled substance in
the course of professional practice.'' 21 U.S.C. 802(21). Second, in
setting the requirements for obtaining a practitioner's registration,
Congress directed that ``[t]he Attorney General shall register
practitioners . . . if the applicant is authorized to dispense . . .
controlled substances under the laws of the State in which he
practices.'' 21 U.S.C. 823(f).
Moreover, because ``the controlling question'' in a proceeding
brought under 21 U.S.C. 824(a)(3) is whether the holder of a DEA
registration ``is currently authorized to handle controlled substances
in the [S]tate,'' Hooper, 76 FR at 71371 (quoting Anne Lazar Thorn, 62
FR 12847, 12848 (1997)), the Agency has also long held that revocation
is warranted even where a practitioner has lost his state authority by
virtue of the State's use of summary process and the State has yet to
provide a hearing to challenge the suspension. Bourne Pharmacy, 72 FR
18273, 18274 (2007); Wingfield Drugs, 52 FR 27070, 27071 (1987). Thus,
even assuming that Respondent's pharmacy license is not expired but is
still active and suspended, it is of no consequence that the TSBP has
suspended Respondent's
[[Page 24350]]
pharmacy license and that Respondent may prevail in a future state
hearing. What is consequential is the fact that Respondent is not
currently authorized to dispense controlled substances in Texas, the
State in which it is registered.\3\ See GX2 to Govt. Mot. (Sept. 15,
2017 TSBP Order), at 4-5. Accordingly, Respondent is not entitled to
maintain its DEA registration.
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\3\ In its brief opposing summary disposition, Respondent argued
that the TSBP ``abused it's [sic] discretion in granting the
temporary suspension . . . because the evidence shows that an agent
of the DEA entrapped the Pharmacy in[to] committing a violation of
the Controlled Substance[s] Act by intentionally failing to inform
the Registrant that'' it was filling prescriptions for a
practitioner who ``was not authorized to issue these
prescriptions.'' Resp. Br. at 2. Respondent's claim relates to its
challenge to the merits of the TSBP's decision to suspend
Respondent's Texas pharmacy license, and I agree with the CALJ that
Respondent has failed to show why or how this claim relates to
whether Respondent is currently authorized to dispense controlled
substances in the State of Texas. See R.D. at 3 n.1.
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I will therefore adopt the CALJ's recommendation that I revoke
Respondent's registration and deny any pending applications to renew
its registration. R.D. at 6. I will also deny any pending application
to modify its registration, or any pending application for any other
DEA registration in Texas, as requested in the Show Cause Order. Order
to Show Cause, at 1.
Order
Pursuant to the authority vested in me by 21 U.S.C. 823(f) and
824(a), as well as 28 CFR 0.100(b), I order that DEA Certificate of
Registration No. FH1729942, issued to Health Fit Pharmacy, be, and it
hereby is, revoked. I further order that any pending application of
Health Fit Pharmacy to renew or modify the above registration, or any
pending application of Health Fit Pharmacy for any other DEA
registration in the State of Texas, be, and it hereby is, denied. This
Order is effective immediately.\4\
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\4\ For the same reasons which led the TSBP to suspend
Respondent's Texas pharmacy license, I conclude that the public
interest necessitates that this Order be effective immediately. 21
CFR 1316.67.
Dated: May 17, 2018.
Robert W. Patterson,
Acting Administrator.
[FR Doc. 2018-11268 Filed 5-24-18; 8:45 am]
BILLING CODE 4410-09-P