Regulations of the Department of Public Health at 105 CMR 700.004 (B)(5) permit residents and clinical fellows who have limited medical licenses and wish to prescribe, dispense and administer controlled substances to utilize the registration of the hospital in which he/she is employed provided the following criteria are met:

  • A person must be authorized to dispense controlled substances under M.G.L. c. 112, if applicable;
  • Such dispensing must be done in the usual course of business or professional practice;
  • The hospital by whom a person is employed must verify with the Board of Registration in Medicine that the individual is permitted to dispense controlled substances;
  • The person must only act within the scope of his/her employment at the hospital;
  • The hospital must authorize the person to dispense controlled substances under the registration number of the hospital and designate a specific suffix number to the hospital's registration number preceded by a hyphen for each person authorized; and
  • The hospital must maintain a current list of internal codes and make these codes available at all times to other registrants, the Commissioner and authorized law enforcement agencies.

It should be noted that individual hospitals determine whether or not they wish to permit persons with limited licenses to use the registration of the hospital. Should a hospital determine that they do not want individuals with limited licenses to utilize the hospital's registration, the physician must apply to the Department and, where applicable, the U.S. Drug Enforcement Administration (DEA), and receive Controlled Substances Registrations for the period of time for which their limited license is issued. Upon full licensure by the Board of Registration in Medicine, a physician must then reapply to the Department, and, where applicable, to the DEA for a new full registration(s). The appropriate fee must accompany the application to the Department. The newly issued registration will not be restricted to the period of time in which the limited license was valid.


This information is provided by the Drug Control Program within the Department of Public Health.