DEA Releases Rule: Protecting Patient Access to Emergency Medications Act of 2017 (PPAEMA)

February 5, 2026

DEA Releases Rule: Protecting Patient Access to Emergency Medications Act of 2017 (PPAEMA)

On Thursday February 5, 2026, the Drug Enforcement Administration (DEA) officially published its long-awaited final rule implementing the Protecting Patient Access to Emergency Medications Act of 2017 (PPAEMA). This rule codifies the statutory framework enacted in 2017 and provides critical regulatory clarity for Emergency Medical Services (EMS) agencies nationwide, and the rule will go into effect 30 days after its official publication.

The following summary of these regulations was prepared by NAEMSP’s consultant, Holland & Knight LLP. EMS physicians and EMS agency managers/administrators should refer to the full published regulations for additional details.

A. Key Definitions (21 CFR 1300.06)

  • DEA adds a dedicated EMS definitions section, including “emergency medical services agency,” “emergency medical services professional,” “standing order,” “verbal order,” “medical director,” and “authorizing medical professional.”
  • Two new operational terms—actively in use and on call—define when an EMS vehicle may store controlled substances away from a registered/designated location.
  • The rule broadens “stationhouse” to mean an enclosed structure in a state where the EMS agency is registered, actively and primarily used by that agency, which may (but need not) house EMS vehicles at its premises.
  • This change removes the NPRM’s requirement that vehicles be physically housed inside the building, addressing urban and rural models where vehicles stage outside or supplies are centralized.

B. EMS Agency Registration Model (21 CFR 1301.13, 1301.20)

  • DEA creates a new “Emergency Medical Services Agency” registration category, with a three‑year fee equal to other dispenser registrations ($888).
  • An EMS agency may choose a single DEA registration per state instead of separate registrations for each station, so long as it is authorized under that state’s law.
  • Hospital‑based EMS agencies may continue to operate under the hospital’s existing practitioner registration and are not required to obtain a separate EMS agency registration.
  • This is a structural shift: DEA will recognize the EMS agency as the registrant, rather than forcing workarounds through individual physicians or hospital-only constructs.

C. Designated Locations / Stationhouses (21 CFR 1301.20(b), 1301.12(b)(5))

  • Registered EMS agencies may deliver controlled substances from their registered location to unregistered “designated locations” that qualify as stationhouses.
  • To do so, the agency must identify each designated location (name and physical address) via DEA’s website and wait 30 days before first delivery.
  • Deliveries from a registered EMS location to its own designated locations are not treated as “distribution” requiring a distributor registration.
  • Designated locations are thus the DEA-recognized footprint where controlled substances may be stored, and EMS vehicles may be staged for medication use.

D. Security & Storage, Including Jump Bags (21 CFR 1301.80)

  • Controlled substances may be stored only at: (1) a registered EMS location; (2) a designated location; (3) an EMS vehicle at a registered or designated location; or (4) an EMS vehicle traveling from/to such a location while responding to an emergency or otherwise “actively in use.”
  • Vehicle locking. An EMS vehicle storing controlled substances must be locked when: Parked outside an enclosed registered/designated location, or actively in use but unattended during non‑emergency stops (e.g., meals, breaks).  The vehicle need not be locked when it is parked within an enclosed registered or designated location, at the scene of an emergency, or attended by EMS personnel (e.g., in transit, public demonstrations).
  • Storage components. Except when drugs are being carried in a jump bag/on person during an emergency (below), controlled substances must be stored in either: a securely locked, substantially constructed cabinet or safe that cannot be readily removed, located at a permitted storage site; or an automated dispensing system (ADS) at a registered or designated location, installed and operated by the EMS agency, not used to dispense directly to patients, and compliant with state law.
  • Jump bags / on-person carriage. EMS personnel may carry controlled substances on their person or in a jump bag while responding to an emergency. Once not actively engaged in an emergency, those drugs must be returned to an approved storage component in the vehicle or at a registered/designated location.
  • The rule therefore permits true scene‑side access (jump bags) but insists on locked, fixed storage when the unit is not actively working a call.

E. Administration Under Standing and Verbal Orders (21 CFR 1306.07(g); 1300.06)

  • An EMS professional of a registered EMS agency may administer (not prescribe) Schedule II–V controlled substances outside the physical presence of a medical director or authorizing medical professional if: authorized by the law of the state where care is provided; and done under either a standing order or a verbal order that meets specified criteria.
  • Standing orders must be written medical protocols in which a medical director prospectively defines the clinical criteria for administration.
  • Standing orders may be developed by a state authority and then issued/adopted by the agency medical director.
  • The EMS agency must maintain records of such orders at a registered location.
  • Verbal orders are real‑time directives given by radio, phone, or other communication from a medical director or other “authorizing medical professional” (e.g., appropriately registered physicians, APRNs, PAs whose state scope includes issuing such orders).  They must be given for a specific patient, either in a mass casualty incident or as needed to ensure proper care of an individual patient.
  • This section is the core federal authorization for modern EMS medical control under PPAEMA, formalizing standing and verbal orders in regulation.

F. Restocking & Emergency Transfers (21 CFR 1307.14, 1307.15)

  • Hospital restocking. Any registered EMS agency may receive controlled substances from a hospital for the purpose of restocking a vehicle after an emergency response, without using DEA Form 222, if: the EMS registered or designated location maintains records of the receipt; the hospital maintains records of the delivery; and if the vehicle is primarily based at a designated location, that location notifies the agency’s registered location within 72 hours of restocking.
  • Emergency inter‑facility deliveries. Hospitals and EMS registered/designated locations may deliver controlled substances to one another, with written approval from the DEA Special Agent in Charge or DEA Headquarters, in cases of: shortages, public health emergencies, or mass casualty events. These mechanisms legitimize common-sense resupply and mutual-aid practices that previously lived in a legal gray area.

G. Recordkeeping (21 CFR 1304.03, 1304.04, 1304.27)

  • EMS agencies must maintain, in readily retrievable form, documentation required by state law describing each EMS professional’s authority to administer or dispense controlled substances (e.g., protocols, practice agreements). 
    They must keep complete records of all controlled substances received, administered, transferred, and destroyed, and records must be kept at each registered and designated location that handles controlled substances.
  • For each dose administered or disposed of, records must include:
    • Drug name, form, date, amount administered or disposed;
    • Patient identifier (if applicable);
    • Last name or initials of the administering EMS professional;
    • Last name or initials of the medical director or authorizing professional who issued the standing/verbal order;
    • Manner of disposal and identities of disposer and witness (if applicable).
  • Separate elements are specified for acquisitions from other registrants, deliveries between registered and designated locations, and destruction events.
    Designated locations must notify their registered location within 72 hours whenever they receive controlled substances via hospital restocking or from another designated location.
  • DEA explicitly changed the NPRM’s “initials only” language to “last name or initials,” and notes that medical directors do not need to personally initial every record so long as they can be clearly identified. 
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