If you hold a DEA registration to prescribe controlled substances, the MATE Act training requirement came due at a single point rather than on a recurring schedule. It is satisfied at what the statute calls your “first applicable registration”: the first new DEA registration or renewal you filed on or after June 27, 2023. It is not annual, it is not attached to your state license, and it does not return at your next renewal.
Here is the operational answer in DEA’s own words. The Drug Enforcement Administration describes the rule this way: “The Consolidated Appropriations Act of 2023 enacted a new one-time, eight-hour training requirement for all DEA-registered practitioners, except veterinarians, on the treatment and management of patients with opioid or other substance use disorders.” The statutory language is “at least 8 hours of training (inclusive or incremental) with respect to the treatment and management of patients with opioid or other substance use disorders.” You affirm it by checking a box on DEA Form 224 (new registration) or DEA Form 224a (renewal). You do not submit a certificate to DEA.
The requirement was created by section 1263(a) of the Consolidated Appropriations Act, 2023 (Pub. L. 117-328), enacted December 29, 2022, and is codified in the Controlled Substances Act at 21 U.S.C. § 823(m)—formerly § 823(l), the citation DEA’s 2023 guidance still uses. Later public laws redesignated the subsection; the substance did not change. Every regulatory statement below was verified against DEA and U.S. Code sources on September 17, 2026.
What the eight hours have to be about
The subject matter is fixed by statute: the treatment and management of patients with opioid or other substance use disorders. It is not eight hours of “pain management” in the broad sense: a course on interventional technique, however substantial, does not answer the question DEA is asking.
The parenthetical—“inclusive or incremental”—works in your favor and is often missed. The eight hours need not come from one course, one provider or one sitting; you may assemble them across qualifying activities. DEA also states that qualifying training may be delivered “in classroom settings, seminars at professional society meetings, or virtual offerings,” so format is not restricted either.
When you attest, and how
The requirement took effect June 27, 2023. DEA states that it “applies to all qualified practitioners when they apply for a new registration or a renewal of registration on or after that date.” The statute sets that trigger date at 180 days after December 29, 2022.
Mechanically it is a checkbox. DEA modified its forms for the purpose: “DEA has modified the DEA Form 224 and DEA Form-224a applications for registration/renewal, in order for practitioners to attest to the training standards at their first applicable registration.” On certificates, DEA is explicit: “It is recommended that each practitioner keep a record of training certificates… However, these documents will not need to be submitted to DEA for review at the time of initial application or renewal.” Keep them in your own credentialing file, but do not go looking for an upload portal.
One time means one time
Two of the most common statements circulating about this rule are that you must repeat the eight hours at every renewal, or every three years. Both are wrong. DEA’s guidance says plainly: “This one-time training requirement affirmation will not be a part of future registration renewals.”
The affirmation is a single event tied to your first applicable registration, not a recurring CME obligation. Your state board may impose a recurring opioid CME duty, but that is a separate obligation.
Who must attest, and who is genuinely exempt
Precision matters most here, because “exempt” is used loosely in almost everything written about the MATE Act. DEA’s answer is short: “All DEA-registered practitioners, with the exception of practitioners that are solely veterinarians.” The statute defines a “qualified practitioner” as one licensed under state law to prescribe controlled substances and who “is not solely a veterinarian.” That is the only blanket exemption.
Nurse practitioners and physician assistants are not exempt. Neither are dentists or podiatrists. If you hold a DEA registration and are not solely a veterinarian, the requirement reaches you.
Separately—and this is a different legal concept—DEA identifies two groups it says are “deemed to have satisfied this training.” Group 1 is physicians board certified in addiction medicine or addiction psychiatry by the American Board of Medical Specialties, the American Board of Addiction Medicine, or the American Osteopathic Association. Group 2 is clinicians who graduated in good standing from a U.S. medical (allopathic or osteopathic), dental, physician assistant, or advanced practice nursing school within five years of June 27, 2023, where the curriculum included at least eight hours of the required content.
Read those as deemed-satisfied pathways, not as exemptions from attesting. A board-certified addiction medicine physician still checks the box at the first applicable registration; they simply rely on the certification rather than a course transcript. “Addiction specialists are exempt from the MATE Act” misstates the obligation.
Training you already completed probably counts
Prior training is not wasted. DEA states that “if you received a relevant training from one of the groups listed below—prior to the enactment of this new training obligation on December 29, 2022—that training counts towards the eight-hour requirement.” Nothing requires the hours to postdate the statute.
The same applies to the old DATA-Waiver pathway: “Past DATA-Waived trainings count towards a DEA registrant’s 8-hour training requirement.” For many prescribers who practiced through that era the hours are already on the shelf, and the work is documentation rather than coursework. Pull the certificates, confirm the provider and the hours, and file them.
Not every eight-hour CME course qualifies
“Any eight hours of CME will do” is the most consequential misreading of this rule, and it fails on two counts: the training must come from a qualifying entity, and it must cover the required subject matter.
Ready to put this into practice?
Explore Empire's hands-on, CME-accredited Pain Management & Interventional Therapies courses — live patients, expert faculty, and ongoing mentorship.
On the source, DEA lists accredited groups whose training satisfies the requirement: the American Society of Addiction Medicine, the American Academy of Addiction Psychiatry, the American Medical Association, the American Osteopathic Association (or AOA-accredited CME providers), the American Dental Association, the American Association of Oral and Maxillofacial Surgeons, the American Psychiatric Association, the American Association of Nurse Practitioners, the American Academy of PAs, and the American Nurses Credentialing Center. DEA also accepts any other organization accredited by the Accreditation Council for Continuing Medical Education or the Commission for Continuing Education Provider Recognition, directly or through an ACCME- or CCEPR-recognized state medical society, and any other organization approved or accredited by the HHS Assistant Secretary for Mental Health and Substance Use, ACCME, or CCEPR.
So the practical test has two questions. Is the accredited provider one DEA names, or an organization accredited by ACCME or CCEPR? And does the content address the treatment and management of patients with opioid or other substance use disorders? If you cannot answer both from the activity’s own accreditation statement, ask the provider in writing before you count the hours. That is the same discipline involved in evaluating any accredited pain management CME program.
What happens if you do not attest
Here is what is known, and where the published record stops. DEA describes the issuance sequence: “After a practitioner attests to the completion of the CAA’s training requirement, if DEA approves the new or renewal application for registration, the new certificate of registration will be issued.” The statute frames the training as “a condition on registration” to dispense controlled substances in schedules II through V.
What DEA’s published guidance does not state is a penalty. As of September 17, 2026, no DEA enforcement policy document setting out a specific sanction, fine or revocation process for non-attestation could be located. Articles telling you DEA will revoke your registration or fine you a named amount are describing something DEA has not published. Build your compliance plan around completing and documenting the hours, not around a penalty figure.
One caveat on currency. DEA’s MATE Act Q&A page still carries a 2023 guidance control number, and whether the exact attestation wording on Forms 224 and 224a has changed since 2023 could not be confirmed as of September 17, 2026. Read the attestation language on the form in front of you when you file, rather than a description of it—including this one.
A federal registration condition is not state CME
These are two obligations with two mechanisms, and conflating them is a real risk. The MATE Act requirement is a condition on your federal DEA registration—the statute says so directly—and you satisfy it by attesting on DEA Forms 224 or 224a. State pain-management and opioid-prescribing CME mandates are conditions on your state license, set by state law and state licensing boards, differing state to state and changing frequently, sometimes between renewal cycles.
They can overlap. One eight-hour ACCME-accredited course on managing patients with opioid use disorder may be applicable to both. But satisfying your state requirement does not discharge the DEA attestation, and the attestation does not discharge your state requirement: different deadlines, different mechanisms, different consequences. To work out what your license requires, start with our post on pain management CME requirements by state, then verify with your own board, the only authority on that question. The same date-stamped habit applies to DEA’s telemedicine prescribing rules, which run on temporary rules with expiration dates—see what is allowed in telehealth pain management.
Frequently asked questions
What is the MATE Act training requirement?
It is a one-time, eight-hour training requirement for DEA-registered practitioners on the treatment and management of patients with opioid or other substance use disorders, created by section 1263(a) of the Consolidated Appropriations Act, 2023 and codified at 21 U.S.C. § 823(m) (formerly § 823(l)). It took effect June 27, 2023 and is satisfied by attesting on DEA Form 224 or 224a at your first registration or renewal on or after that date.
Who is exempt from the MATE Act requirement?
DEA states the requirement applies to “all DEA-registered practitioners, with the exception of practitioners that are solely veterinarians.” That is the only blanket exemption, and nurse practitioners and physician assistants are not exempt. DEA separately identifies two groups it deems to have already satisfied the training—certain addiction medicine and addiction psychiatry board-certified physicians, and recent graduates of qualifying U.S. programs—but those practitioners still complete the attestation.
Does training I completed before the law passed count?
Yes. DEA states that relevant training from a listed group received before the December 29, 2022 enactment “counts towards the eight-hour requirement,” and that “past DATA-Waived trainings count towards a DEA registrant’s 8-hour training requirement.” Hours may also be accumulated across several activities, because the statute allows training that is “inclusive or incremental.”
What training qualifies for the DEA eight hours?
Training from one of the accredited groups DEA names—including ASAM, AAAP, the AMA, the AOA, the ADA, AAOMS, the APA, AANP, AAPA and ANCC—or from any organization accredited by ACCME or CCEPR; and the content must address opioid or other substance use disorder treatment and management. Format is not restricted: DEA accepts classroom, professional-meeting and virtual delivery. Not every eight-hour CME activity qualifies.
How is this different from my state’s opioid CME requirement?
The MATE Act requirement is a condition on your federal DEA registration, attested once on DEA Forms 224 or 224a. State opioid and pain CME requirements are conditions on your state license, set by your board, and often recurring. One course may be applicable to both, but neither obligation satisfies the other. Confirm your state’s current rule with your licensing board.
Where Empire’s pain management training fits
Empire Medical Training does not represent that any of its courses satisfy the MATE Act eight-hour requirement, and you should be cautious with any provider that makes that claim without showing you the accreditation statement. Apply the two-part test above to every activity you consider, ours included: identify the accredited provider, then read the content description against DEA’s subject matter. If either half is unclear, ask in writing.
What Empire’s pain curriculum is built for is the clinical and procedural side of pain practice. Pain Management Training, known as THE Pain Show, is accredited for 25.25 AMA PRA Category 1 Credits™ and is jointly provided by AKH, Inc, and Empire Medical Training. Activities certified for AMA PRA Category 1 Credits™ must be certified by an organization accredited by the ACCME or by a recognized state medical society—which is the accreditation statement you should be reading on any program, and the first of DEA’s two questions. The second, subject matter, is specific to the activity, so ask before counting hours toward the DEA eight.
For the clinical material itself, our clinical reference on interventional pain management procedures maps the field by anatomic target and procedure class with an evidence verdict for each, and the pain management training catalog shows how the programs sequence. If you are weighing procedural CME against a formal training pathway, read CME-accredited pain training versus a pain medicine fellowship first—the two credentials do different things. Clinicians building procedural skills alongside their compliance hours often start with trigger point injection training and certification or pain management certification for nurses.
