On February 5, 2026, the Drug Enforcement Agency (DEA) published the final rule implementing the Protecting Patient Access to Emergency Medications Act of 2017 (PPAEMA). The rule takes effect March 9, 2026. For fire-based EMS, this rule matters because it aligns federal controlled-substance requirements with how we operate: distributed stations, mobile units, and protocol-driven care.
Key Takeaways for Fire-Based EMS
- A clear EMS registration pathway
PPAEMA formally establishes an EMS agency registration framework for handling controlled substances. Multi-state operations generally require separate registrations in each state where the agency operates.
- Government fire-based EMS is fee-exempt
DEA confirms that government-operated agencies (including most municipal fire departments providing EMS) are exempt from DEA application fees.
- Standing orders and verbal orders are explicitly recognized
EMS clinicians may administer Schedule II–V medications outside the medical director’s physical presence when authorized by state law and done under valid standing orders or verbal orders. The rule also emphasizes maintaining standing-order records at the registered location.
- “Hub-and-spoke” delivery with stationhouse designation
A registered EMS agency may move controlled substances from a registered location to an unregistered location only if that site is designated as a stationhouse and DEA is notified at least 30 days before the first delivery. DEA also clarifies that distributors cannot deliver directly to those unregistered locations under this framework.
- Field practicality: jump bags and on-person carry during emergencies
DEA allows controlled substances to be carried on-person or in a jump bag during active emergency response, with the expectation that medications return to secure storage when not actively responding.
- Disaster/shortage flexibility with DEA approval
The rule includes limited pathways for hospitals and EMS agencies to transfer controlled substances during shortages, public health emergencies, or MCI situations, but it requires written DEA approval.
What Fire Chiefs and EMS Leaders Should Do Now
- Confirm your registration model and which stations should be designated as stationhouses.
- Ensure standing orders/verbal order policies are current, signed, and well-documented.
- Update storage/jump bag/vehicle security SOPs and reinforce training and audits.
Bottom line
PPAEMA modernizes DEA rules to support patient access to time-critical controlled medications while keeping strong accountability, especially important in fire-based, multi-station EMS systems.
For more information, please see the additional article written by our partners at the National Association of EMS Physicians (NAEMSP) and the final PPAEMA rule.