What Happened

DEA revoked a Pennsylvania psychiatrist's registration by final Decision and Order published October 19, 2026, after finding that he prescribed a Schedule II stimulant to an undercover law enforcement officer on three occasions without an accurate and complete evaluation, and then falsified her patient records.

DEA issued an Order to Show Cause on November 30, 2023, alleging that the psychiatrist's continued registration in Easton, Pennsylvania was inconsistent with the public interest and that falsifying patient records to conceal unlawful prescribing threatens public health or safety. This was a final agency decision after adjudication, not a default: the psychiatrist requested a hearing, the administrative law judge terminated the proceeding for delay in August 2024, the Administrator declined to enter a default in July 2025 and returned the matter to the Government, and a new Request for Final Agency Action followed in August 2025. The Agency then made its findings on the record.

On May 17, 2021, the officer paid $300 in cash for a first visit, where students working at the practice interviewed her about her medical history. She said she did not know whether she had a history of ADHD and that she had no identification card because it had been revoked after a DUI arrest. She told the psychiatrist that another doctor had prescribed dextroamphetamine-amphetamine two to three years earlier and that she wanted it again because it helped her "get along better." He checked the Pennsylvania prescription drug monitoring program, which showed no controlled substance prescribed to her in the prior five years, and prescribed 30 tablets of dextroamphetamine-amphetamine 5 mg, two times daily for 15 days, without diagnosing or specifying a condition and without counseling her about one.

On June 11, 2021, she spoke only with staff. After a student relayed that the medication "just did not last throughout the day," the psychiatrist increased the strength to 10 mg two times daily and prescribed 60 tablets without speaking to or re-evaluating her; his progress note recorded the encounter as a "secure video" visit. On August 9, 2021, again with staff contact only, the strength was raised to 15 mg two times daily, 60 tablets, again without speaking to or re-evaluating her. That progress note recorded both "telehealth" and "Office Visit in person," and the prescription carried diagnoses of major depressive disorder and ADHD that the visit transcripts do not reflect. The state monitoring program confirmed prescriptions written and filled on all three dates.

After DEA subpoenaed the patient records in September 2023, the psychiatrist produced intake forms, screening instruments (including the PHQ-9, GAD-7 and an adult ADHD self-report scale), a 12-panel urine drug screen result and a Test of Variables of Attention result. The officer declared under penalty of perjury that she never completed those forms, never provided a urine specimen on either date, and that her signature had been copied from a form she did sign onto forms she never filled out. The Agency credited her declaration and found substantial record evidence that the records, including numerous diagnostic tests, were falsified. It also found that the psychiatrist had not accepted responsibility and that the falsification during the investigation showed a lack of candor.

DEA revoked the registration and denied any pending application to renew, modify or obtain an additional Pennsylvania registration. The order was signed October 5, 2026 by the DEA Administrator and takes effect November 18, 2026.

What Went Wrong

  • A controlled stimulant was prescribed on the first visit with no diagnosis recorded. The psychiatrist prescribed without diagnosing or specifying the patient's condition and without counseling her about one.
  • Two dose escalations occurred with no clinician contact. The strength rose from 5 mg to 10 mg to 15 mg on staff relays alone, without speaking to or re-evaluating the patient.
  • Students relayed clinical information and dose changes. Students working at the practice took the history and passed along the report that the medication did not last, which became the basis for a higher dose.
  • Documentation did not match the encounter. Progress notes recorded a "secure video" visit, and later "telehealth" and "Office Visit in person," for contacts that were staff-only, and the August prescription carried diagnoses the visit transcripts do not reflect.
  • A monitoring program check was performed and then disregarded. The prescription drug monitoring program showed no controlled substance prescribed to the patient in five years, yet a Schedule II stimulant was prescribed at the first visit.
  • The falsification turned a prescribing-record problem into a candor problem. Records produced after a subpoena included forms the patient never completed, a copied signature and test results for tests she never took. The Agency treated this as a lack of candor and as a basis for the sanction.

How It Could Have Been Prevented

  • Require, and audit for, a documented diagnosis before the first controlled-substance prescription is issued.
  • Require a documented evaluation by the prescriber before any dose increase, rather than accepting a staff relay that a medication is not working.
  • Restrict who may relay or authorize prescription changes, and keep students and non-prescribing staff out of dose decisions.
  • Verify the recorded encounter type (telehealth versus in-person) against actual contact, such as call logs, video session records and visit transcripts.
  • Reconcile signed intake forms and test results against source records during internal audit, including whether a urine specimen and a testing session actually occurred on the dates charted.
  • Treat a negative prescription drug monitoring program history as a reason for more scrutiny of a new controlled-substance request, not less.
  • Preserve records under a litigation hold with audit trails, so that alterations or additions made after a subpoena are detectable.

Related Guidance

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