Streamline CSR Permit Requirements

TMA Testimony by Richard Benedikt, MD

House Homeland Security and Public Safety
House Bill 1803 by Rep. Bill Callegari
March 28, 2013

Mr. Chairman, members of the committee, I am Dr. Richard Benedikt. I am a radiologist in San Antonio, and I am here today representing the 47,000 physician and medical student members of the Texas Medical Association.

I speak strongly in support of House Bill 1803. This is a very simple bill but affects every physician in Texas — in a very good way. Our thanks to Representative Callegari for his sponsorship of this bill. It really is a “red tape” reduction bill. 

To prescribe medications to our patients, physicians must have a Controlled Substances Registration — a “CSR permit”— issued by the Department of Public Safety (DPS) before we can receive a permit from the U.S. Drug Enforcement Administration (DEA). Since its inception, the CSR has been an annual permit that requires filling out a paper renewal form and mailing a check to DPS.

In contrast, I can renew my medical license — issued by the Texas Medical Board and valid for two years — online.

House Bill 1803 simply does this: It makes the annual CSR a two-year permit, syncs it to the expiration of my medical license, and allows me the opportunity to start the renewal process ONLINE with the renewal of my medical license! Very simple, very efficient — one-stop shopping.

It is worth supporting only for the simplicity of renewing both items online. But the added benefit, I believe, is an easier system for DPS. Instead of dealing with several thousand paper renewals each month,  instead it will receive — on a quarterly basis — the electronic renewal data from the Texas Medical Board.

It also should make the possibility of a lapse in the physician’s CSR permit fairly remote. And here is the really important part: If a physician’s CSR permit lapses, the DEA permit becomes invalid. Without that, a physician cannot prescribe. Patient care suffers. And, because the physician’s credentials are NOT up to date … that physician will lose hospital medical staff privileges and, likely, participation in various health insurance panels. This cascading series of events is bad for patient care … and disastrous to a physician’s practice.

In short, this is an excellent proposal. The Texas Medical Board can make the necessary changes to its online renewal. DPS is willing to makes these changes to its permitting process to simplify renewal. And the physicians of Texas will love it. We ask for your vote in favor of HB 1803.

83rd Texas Legislature Letters and Testimonies main page 


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