DEA Revokes an Indiana Nurse Practitioner's Controlled Substance Registration, Citing Opioids Prescribed by Telehealth Without an In-Person Exam

The Drug Enforcement Administration has revoked the controlled substance registration of Katherine Curtis, a nurse practitioner in Carmel, Indiana, in a Decision and Order published in the Federal Register on October 14, 2026. The agency concluded that keeping her registration would be inconsistent with the public interest and that she no longer holds the Indiana authority a registrant must have to handle controlled substances.

The order is short on drama but specific on facts. It describes monthly opioid, stimulant, and sedative prescriptions written for six patients over roughly a year, several of them issued by telehealth without the in-person examination Indiana law requires before an opioid can be prescribed that way. For telehealth clinicians and the platforms that employ them, the decision is a plain restatement of where federal and state prescribing rules meet.

What the DEA decided

On December 15, 2025, the DEA issued an Order to Show Cause proposing to revoke Curtis's DEA Certificate of Registration No. MS5411765. The order alleged two things: that she was then without authority to prescribe, administer, or dispense controlled substances in Indiana, the state where she is registered with the DEA, and that she had issued multiple prescriptions that were not for a legitimate medical purpose and did not meet the Indiana standard of care. After reviewing the record, the agency granted the government's request for final action and revoked the registration. The order takes effect November 13, 2026.

Two independent grounds

Loss of state authority

A DEA registration rests on state authority to handle controlled substances. According to the order, Curtis's Indiana advanced practice registered nurse license and her Indiana controlled substance registration both expired by their own terms on October 31, 2025, and her advanced practice license was then suspended on November 20, 2025. Indiana requires a practitioner to hold a state controlled substance registration to dispense controlled substances there. Because she no longer held one, the DEA found she lacks state authority, which under 21 U.S.C. 824(a)(3) is an independent basis to revoke a federal registration regardless of anything else in the record.

Prescriptions outside the usual course of practice

The agency also made public interest findings under 21 U.S.C. 823(g)(1). From June 2024 to May 2025, the order found, Curtis repeatedly issued controlled substance prescriptions to six patients that lacked a legitimate medical purpose and fell outside the usual course of professional practice in Indiana. The drugs named include Schedule II opioids such as oxycodone, oxycodone with acetaminophen, hydrocodone with acetaminophen, and fentanyl, the Schedule II stimulant dextroamphetamine and amphetamine, benzodiazepines such as clonazepam and alprazolam, the sedative zolpidem, tramadol, pregabalin, and the Schedule III anesthetics ketamine and esketamine. The order describes overlapping combinations of opioids, stimulants, and sedatives, esketamine ordered in excess of recommended amounts, and high opioid doses written for a patient with no prior opioid history. A DEA medical expert who reviewed the records concluded the prescriptions violated the minimal medical standards that apply to practice in Indiana.

The telehealth finding

The telehealth element is narrow and concrete. Indiana law prohibits a prescriber from issuing an opioid prescription through telehealth when the prescriber has not previously examined the patient in person. The agency found that Curtis issued opioid prescriptions to four of the six patients, identified in the order by initials, through telehealth without first examining them in person. The order also found that she failed to establish a proper provider and patient relationship, to take an adequate medical history, and to consult Indiana's prescription drug monitoring program, known as INSPECT, before prescribing opioids to some patients. Those are the building blocks of a legitimate prescription, and the order treats their absence, not the use of telehealth by itself, as the problem.

A default case

The procedural posture matters for how much weight to give the findings. Curtis did not request a hearing within the time the rules allow, so the DEA found her in default. Under its regulations, a registrant who fails to request a hearing is deemed to have waived it and to have admitted the factual allegations in the Order to Show Cause. The government filed a request for final agency action on February 4, 2026, and the agency decided the case on the written record. The findings therefore reflect allegations the agency deemed admitted by default and the conclusions of its reviewing expert, not facts tested at a contested hearing or proven to a jury.

What this means for telehealth prescribers

Nothing in the order changes the law. It applies settled rules: a federal registration follows state authority, and a controlled substance prescription has to come from a real clinical evaluation. The telehealth detail is a reminder that state law can require an in-person examination before an opioid is prescribed online, and that a prescriber who skips it is exposed on both the state and the federal side. For the platforms that route controlled substance prescriptions through individual clinicians, the decision underlines that the clinician's lapsed license or skipped exam becomes the company's compliance problem the moment a prescription issues. This is general information, not legal or medical advice; clinicians and operators with specific questions should consult counsel and their state licensing board.

Limits of this decision

A Decision and Order is an administrative action by the DEA about one registrant's prescribing authority. It is not a criminal conviction, a fine, or a court ruling, and it does not by itself bar Curtis from practicing nursing where a state license allows. The order notes that a registrant may ask the agency to reconsider its factual findings by filing a properly supported motion within a short window after the decision. Because the case went by default, it sets no contested precedent, and the patient details are limited to what the agency recited in the published order.