What Happened
Xiang Yuan, M.D., a physician practicing in Pottstown, Pennsylvania, agreed to pay $100,000 to resolve allegations that he violated the Controlled Substances Act through recordkeeping and prescribing practices.
The government alleged Yuan failed to keep complete and accurate records of controlled substances, wrote prescriptions "for stock" rather than for identified patients, and improperly moved controlled substances from his registered practice address. These practices are prohibited because DEA registration and recordkeeping requirements are tied to a specific, identifiable patient and a specific, registered location.
The settlement, announced July 2, 2026, requires Yuan to pay $100,000 and enter a three-year Memorandum of Agreement with DEA imposing compliance obligations stricter than the underlying regulations.
What Went Wrong
A physician's own prescribing and recordkeeping practices departed from Controlled Substances Act requirements in several distinct ways at once. Key failures included:
- Controlled-substance records were not complete or accurate, undermining the ability to reconcile what was prescribed, dispensed, and on hand.
- Prescriptions written "for stock" rather than for a specific, identified patient are not permitted under the CSA's prescribing framework.
- Controlled substances were moved away from the registered practice address without the required registration covering that location.
- These practices persisted until a DEA review, rather than internal compliance processes, identified them.
How It Could Have Been Prevented
- Write controlled-substance prescriptions only for identified, examined patients, never as generic "stock" orders.
- Maintain controlled-substance records that can be reconciled against receipts, dispensing, and on-hand inventory at any time.
- Obtain a separate DEA registration before storing or handling controlled substances at any location other than the registered practice address.
- Periodically self-audit prescribing and recordkeeping practices against CSA requirements rather than waiting for a DEA review to identify gaps.
Related Guidance
- Diversion prevention checklist — Self-assessment covering prescribing documentation and registration requirements.
- Controlled Substance Inventory Requirements — Recordkeeping practices that surface losses and registration obligations by location.
- 15 Red Flags of Drug Diversion — Behavioral and transactional indicators including stock-not-patient prescribing.