Which action is required to legally operate as an online pharmacy with the DEA?

• A. Obtain a modification of registration permitting operation.
• B. Cede all brick-and-mortar licenses to another company.
• C. Publish patient education brochures online only.
• D. Discontinue all controlled substance dispensing.

Answer: (A)

DEA registration for dispensing controlled substances is location- and activity-specific, so moving from a brick-and-mortar setup to online dispensing requires updating that registration to cover online operation. The online activity changes the scope of what the registration authorizes, and a modification is the formal way to reflect that change and meet requirements under the Ryan Haight framework. Without updating the registration, the online operation would not be legally authorized by the DEA. The other options don’t establish the necessary legal authorization for online dispensing: changing licenses, publishing brochures, or stopping controlled substances don’t grant DEA permission to dispense online.