Protecting Your DEA Registration in Texas & Nationwide

Almonte Law- Federal Defense Attorney

Principal Office: San Antonio, Texas

When the DEA asks you to sign DEA Form 104 – Voluntary Surrender of Controlled Substances Registration, your career is on the line.

At Almonte Law, we defend physicians, pharmacists, nurse practitioners, clinics, and healthcare professionals facing DEA investigations, Orders to Show Cause, and registration surrender demands. While our principal office is located in San Antonio, Texas, we represent clients throughout Texas and across the United States in DEA administrative and federal matters.

If the DEA is requesting that you surrender your registration, do not sign anything before speaking with experienced defense counsel.

What Is DEA Form 104?

DEA Form 104 is titled “Voluntary Surrender of Controlled Substances Registration.” By signing it, you immediately give up your DEA registration and your authority to prescribe, dispense, or administer controlled substances.

Key consequences include:

• Immediate termination of DEA prescribing authority
• Loss of ability to handle Schedule II–V medications
• Potential reporting to state licensing boards
• Collateral impact on hospital privileges and employment
• Increased scrutiny in future DEA applications
• Possible admission implications in related investigations

Despite being labeled “voluntary,” Form 104 is often presented during high-pressure interactions with DEA diversion investigators.

Should You Sign DEA Form 104?

In most cases, signing DEA Form 104 is not in your best interest without legal advice.

You may have important rights, including:

• The right to refuse voluntary surrender
• The right to receive a formal Order to Show Cause
• The right to request a hearing before a DEA Administrative Law Judge (ALJ)
• The right to present evidence and challenge allegations
• The right to negotiate terms or corrective measures

Once signed and accepted, reversing a voluntary surrender is extremely difficult.

Our DEA Form 104 Strategy

Every case is different. At Almonte Law, we tailor a defense strategy based on the specific allegations and procedural posture of your case.

Our representation may include:

1. Immediate Intervention

• Communicating directly with DEA investigators
• Advising you before interviews or inspections
• Preventing rushed or uninformed decisions

2. Challenging an Order to Show Cause

• Preparing a formal response
• Requesting an administrative hearing
• Developing evidentiary defenses
• Cross-examining government witnesses

3. Negotiation with DEA Counsel

• Exploring corrective action plans
• Addressing recordkeeping or compliance issues
• Seeking limited sanctions rather than full revocation

4. Coordinating With State Licensing Defense

DEA issues often trigger action by:

• Texas Medical Board
• Texas State Board of Pharmacy
• Texas Board of Nursing
• Other state professional licensing authorities

We strategically manage parallel proceedings to minimize long-term damage.

Who We Represent

We defend:

• Physicians (MD/DO)
• Pain management doctors
• Psychiatrists
• Nurse practitioners & PAs
• Pharmacists
• Clinics & healthcare facilities
• Telemedicine providers
• Out-of-state practitioners facing DEA action

Whether you practice in San Antonio, McAllen, Houston, Dallas, Austin, El Paso, or anywhere else in Texas, or anywhere in the country, we can represent you in DEA administrative proceedings.

Why Choose Almonte Law?

• Focused experience in federal regulatory and administrative defense
• Strategic understanding of DEA enforcement procedures
• Aggressive protection of professional licenses and registrations
• Personalized defense planning
• National representation from our San Antonio principal office

Our goal is simple: protect your registration, your license, and your career.

Common Situations Leading to DEA Form 104 Requests

The DEA may request surrender following allegations involving:

• Prescribing outside the usual course of professional practice
• Alleged overprescribing of opioids or stimulants
• Recordkeeping deficiencies
• Inventory discrepancies
• Failure to maintain effective controls against diversion
• Criminal investigations
• State board disciplinary findings

However, allegations are not convictions, and you are entitled to due process.

Frequently Asked Questions (FAQ)

What happens if I refuse to sign DEA Form 104?

If you refuse, the DEA must proceed formally by issuing an Order to Show Cause. You then have the right to request a hearing before an Administrative Law Judge.

Can I reapply after surrendering my DEA registration?

You may apply again, but prior surrender can significantly impact approval and may require extensive documentation.

Is voluntary surrender better than revocation?

Not necessarily. Each case is fact specific. Sometimes defending the registration leads to better long-term outcomes.

Can I still practice medicine without a DEA registration?

Possibly, but your ability to treat patients may be severely limited depending on your specialty and employer requirements.

Do you represent clients outside Texas?

Yes. While our principal office is in San Antonio, Texas, we represent healthcare professionals nationwide in DEA administrative matters.

Act Before You Sign

If DEA agents have contacted you or presented DEA Form 104:

Do not sign immediately.
Do not provide statements without counsel.
Call an experienced DEA defense attorney.

Early intervention can significantly impact the outcome of your case.

Contact Almonte Law

Almonte Law
Principal Office: San Antonio, Texas
Serving clients throughout Texas and across the United States

📞 Schedule a confidential consultation today. 210-866-3233
Your DEA registration and your professional future may depend on it.