Protecting Patient Access to Emergency Medications Act of 2017 (PPAEMA)
This material is provided for general informational purposes only and does not constitute legal or regulatory advice. EMS physicians and EMS agency managers/administrators should not rely solely on this summary and must consult the full, current published regulations and applicable agency guidance for complete requirements and obligations.
DEA-377 Compliance Checklist for EMS Agencies
https://www.federalregister.gov/documents/2026/02/05/2026-02288/registering-emergency-medical-services-agencies-under-the-protecting-patient-access-to-emergency
1. DEA Registration & Agency Structure
Registration status
☐ Agency has confirmed whether it must hold its own DEA EMS registration
Agency has identified whether it is:
☐ Private EMS (fee-paying)☐ Government EMS (fee-exempt)
☐ Hospital-based EMS (operating under hospital registration)
Registration scope
☐ One DEA registration per state of operation
☐ Separate registrations obtained for each state (if multi-state agency)
☐ Hospital-based EMS confirmed continued coverage under hospital registration
Transition plan (if applicable)
Transition option selected:
☐ Immediate☐ At current registration expiration
☐ 3–6 months prior to renewal
☐ Local DEA field office contacted
☐ Registration owner assigned (name/title)
2. Medical Director & Authorization Framework
Standing orders
☐ Written standing orders in place
☐ Standing orders signed by medical director
☐ Standing orders include controlled substances authorized
☐ Copies retained and readily retrievable
Verbal orders
☐ Policy defines who may issue verbal orders
☐ Verbal orders limited to state-authorized providers
☐ Verbal orders documented per patient encounter
Scope alignment
☐ Agency confirmed compliance with state law for controlled substance administration
☐ EMS scope of practice reviewed and aligned with protocols
3. EMS Vehicles & Controlled Substance Storage
“Actively in use” compliance
☐ Agency policy defines “actively in use” consistent with DEA-377
☐ Vehicles may store controlled substances when:
- Responding to emergency
- Transporting patients
- On call / staged / standby
Locking requirements
☐ SOP specifies vehicles must be locked when:
- Unattended
- Parked outside registered or designated locations
☐ SOP specifies vehicles do not need to be locked when:
- At an emergency scene
- Inside registered/designated locations
- EMS personnel are present
☐ Supervisors trained to enforce locking compliance
4. Stationhouses & Designated Locations
Registered location
☐ Registered location identified and documented
☐ Controlled substance storage meets DEA security standards
Designated locations
☐ All designated locations identified
☐ DEA notified of designated locations as required
☐ Locations used for storage, delivery, or staging are compliant
Facility flexibility
☐ Stationhouses not required to house vehicles indoors
☐ Exterior parking areas properly treated as part of premises
5. Controlled Substance Acquisition & Restocking
Hospital restocking
☐ Policy allows restocking at any hospital, not limited to parent registration
☐ Restocking procedures documented
☐ Hospital pharmacy coordination confirmed
Emergency exchanges
☐ Procedures for shortages, disasters, and MCI medication exchanges defined
☐ Inter-agency and hospital MOUs reviewed (if applicable)
6. Recordkeeping & Documentation (High-Risk Area)
Administration records
Records include:
☐ Drug name☐ Date and time
☐ Patient identifier
☐ Administering EMS professional (last name or initials)
☐ Authorizing medical professional (last name or initials)
Transfer & delivery records
☐ Transfers between registered/designated locations documented
☐ Hospital restocking documented
☐ Loss or theft reporting process defined (DEA Form 106)
Retention & access
☐ Records retained for minimum 2 years
☐ Records stored at registered or designated locations
☐ Records readily retrievable for audit
7. Disposal of Controlled Substances
☐ Disposal complies with 21 CFR Part 1317
☐ Disposal events documented per DEA requirements
☐ Witnessing and documentation procedures defined
☐ Staff trained on disposal process
8. Training & Personnel Accountability
☐ EMS personnel trained on:
-
Controlled substance handling
-
Storage and vehicle security
-
Documentation expectations
-
Standing vs verbal orders
-
Training documented and recurring
-
Supervisors trained on enforcement and audit readiness
9. Quality Assurance & Oversight (Strongly Recommended)
(Not explicitly required, but reduces risk)
☐ Controlled substance administration included in QA/QI program
☐ Medical director participates in QA review
☐ Periodic internal audits conducted
☐ Corrective actions documented and tracked
10. Leadership & Governance
☐ DEA-377 compliance owner designated
☐ Compliance reviewed at executive or board level
☐ SOPs updated to reflect DEA-377 language
☐ Audit readiness confirmed annually
Final Reality Check for Leadership
If you can check 90–100% of these boxes, your agency is:
- DEA-compliant
- Audit-ready
- Protected against regulatory ambiguity
- Operating exactly as DEA intended