As physicians tell the Texas Medical Association about their continued problems getting the Texas Department of Public Safety (DPS) to process their applications for renewal of their controlled substance certificates, TMA continues to press state officials for an explanation. More importantly, TMA continues to press DPS officials to let physicians know what they have to do to get their renewed certificates and when they can expect to receive them.
UPDATE from DPS (Aug. 26, 2011, 5 pm)
A revised version of the application form is now available on the DPS website
- Application for Registration NAR-77-78
- Certificate of Exemption From Fee NAR-80
The new downloadable Application for Registration may be used for new applications as well as renewals and requests for additional locations. The Certificate of Exemption From Fee is now a separate form that should be submitted along with the Application for Registration as necessary.
These forms may be submitted in lieu of the pre-printed forms mailed to our CSR customers
Contact DPS to check on the status of your application.
Here are the questions that TMA posed and the answers from Amanda Arriaga, chief of the DPS Public Affairs and Policy Division.
What is the best way for physicians to get renewal applications to you? Can they be done online? What is your preferred and most convenient mechanism? Can you send explicit instructions?
Renewal applications must be submitted through the mail along with the required fee. The mailing address is preprinted on the application form. We do not have an online application process, but are working toward enhancing the current system to allow for online submission and payment processing. As you know, renewal notices have traditionally been mailed 60 days prior to expiration. Recently, we have expanded the notification process and are now sending notices 90 days prior to expiration and highly encourage applicants to submit the application and fees promptly. Additionally, we are updating the application form and will post it online in the near future. This will allow registrants the opportunity to download the renewal form and mail it to us.
Do you anticipate the same effort at the end of this month as in July to process applications?
As of today's date (Aug. 24), we are current with processing renewal applications. However, we are still receiving a high volume of renewal applications for August expirations. For example, we received more than 300 applications just this past Friday. While those will be processed quickly, this provides the department only eight business days to complete the process. As of today, we still have not received renewal applications for approximately 17 percent of those scheduled to expire in August. Applicants who submit their application as of tomorrow have provided themselves only five business days to complete the process before their licenses expire.
Will DPS grant an extension in the event their renewal is unable to be processed?
We will begin notifying applicants about their impending expiration 90 days in advance, rather than 60 days. As applications are received, we will process them. However, applications that are submitted at the last possible moment may not be renewed before the expiration of the license.
Can DPS create a renewal form in PDF?
The Regulatory Services Division is posting the renewal document in PDF and should have it completed in the next several days.
We're hearing from physicians who cannot get through to DPS, are anxiously awaiting their renewal confirmation, or cannot get through by phone to ask for a renewal application. At the same time, they cannot go to the DPS website to even download and print a renewal form.
The department continues to process renewals in a timely manner. As of Monday, Aug. 22, we were processing applications received by the department the week of the 15th. Therefore, persons who submitted their application more than two weeks prior to expiration will have their applications timely processed, though normal processing time is approximately three to four weeks. Nevertheless, we strive to renew all applications prior to expiration as we understand the work done by these medical professionals. We have checked with our contact center, and there is no influx of phone calls that would indicate individuals not being able to get through on the phone if they are attempting to check status. We reviewed wait times again this afternoon, and as of a few hours ago, it took only eight minutes in the call queue to reach a customer service agent. As the notification of expiration includes the renewal form, the only individuals who would need to download a form would be ones who have lost their original one. In that case, they can contact us and we will immediately send them another renewal form. Please note: If there are physicians who sent in their renewal several weeks ago and have not seen an update, please send us specific names so that we can review their situation and determine if there was any unreasonable delay with their application.
Physicians say they have been unable to reach the manager of the Licensing and Registration Services Department by telephone or by email.
We apologize for the delay. Our manager is doing her best to answer your questions, as well as the others that she receives, in a timely manner.
Even with an apparently new system, this remains a paper-driven process that requires new and renewing applicants to mail (or possibly) fax materials to DPS for the renewal. And with this brings the usual and expected clerical and data entry bottleneck for the department.
We are not able to accept applications by fax because they must be accompanied by the registration fee. If we were to accept an application by fax, the processing still could not begin until the payment is received. The new system improved the activities of our processors to handle the applications internally. Unfortunately, the initial intake of receiving the applications is still paper intensive. We have plans in place to automate the application process in the future, including an online pay function, but as with any state agency, we must prioritize based on limited funds and resources provided.
We still cannot understand, and it's never been explained, why a "new" system cannot allow for secure online renewals. It certainly would relieve the DPS from the clerical burden of dealing with paper renewal forms, manual check processing, handling thousands of phone inquiries, etc.
We may have caused some confusion in conversations about our "new system." There were internal features that were automated to help our processors function more efficiently. However, there was not a new system created solely to address the issue of automation of the Controlled Substance Renewals (CSRs). In sum, our monitoring of CSR renewal applications does not indicate any internal delays. If there are physicians who believe there is an issue with their application, please forward their names and we will look into their specific situations. For applicants who have lost their renewal form, likewise, they can contact us, and we will immediately get another renewal out to them. However, we encourage persons to apply as soon as possible. If the 17 percent of outstanding applications are received with only five business days for the department to process, it may be very difficult to accommodate their requests.
You may check the status of your application online. Enter your DPS number. This should bring up your record. If the expiration date is in 2012, DPS has renewed your certificate. DPS updates the database nightly. DPS will mail a renewal confirmation, but TMA suggests you print a copy of the registration page showing the new 2012 expiration date to prove you have a current DPS registration number.
Special Action: Aug. 27, 2011