[Federal Register Volume 90, Number 87 (Wednesday, May 7, 2025)]
[Notices]
[Pages 19313-19317]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2025-07933]
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DEPARTMENT OF JUSTICE
Drug Enforcement Administration
[Docket No. 25-1]
Peter Dashkoff, M.D.; Decision and Order
I. Introduction
On September 9, 2024, the Drug Enforcement Administration (DEA or
Government) issued an Order to Show Cause and Immediate Suspension of
Registration (OSC/ISO) to Peter Dashkoff, M.D., of Yuma, Arizona
(Respondent). OSC/ISO, at 1. The OSC/
[[Page 19314]]
ISO informed Respondent of the immediate suspension of his DEA
Certificate of Registration (Registration) No. FD3660304, alleging that
Respondent's continued registration constitutes `` `an imminent danger
to the public health or safety.' '' Id. (quoting 21 U.S.C. 824(d)). The
OSC/ISO also proposed the revocation of Respondent's registration,
alleging that Respondent's continued registration is inconsistent with
the public interest. Id. at 1 (citing 21 U.S.C. 823(g)(1),
824(a)(4)).\1\
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\1\ The OSC/ISO also alleged that, pursuant to 21 U.S.C.
824(a)(3), Respondent did not have state authority to handle
controlled substances. OSC/ISO, at 1. However, on December 12, 2024,
the Government filed a Motion for Dismissal of Allegation that
Respondent Lacks State Authority when it learned that Respondent
regained his state authority subsequent to the filing of the OSC/
ISO. Recommended Decision (RD), 2; ALJ Exhibit (ALJX) 26. Based on
this evidence, the Administrative Law Judge (ALJ) found that the
OSC/ISO allegation regarding loss state authority was ``NOT
SUSTAINED.'' Recommended Rulings, Findings of Fact, Conclusions of
Law, and Decision of the Administrative Law Judge (RD), at 10
(emphasis in original).
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Specifically, the Government alleges that on June 26, 2024,
Respondent issued four \2\ controlled substance prescriptions after he
was prohibited from engaging in the practice of medicine in the State
of Arizona. Id. at 3. The OSC/ISO alleged that these prescriptions were
issued outside the usual course of professional practice and violated
federal and state law. Id. at 2-3 (citing 21 U.S.C. 1306.04(a), Ariz.
Rev. Stat. Ann. secs. 36-2522(A), 32-3227(F) & (G)).
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\2\ The OSC/ISO alleged that Respondent issued at least five
controlled substance prescriptions. OSC/ISO, at 3. However, during
the administrative hearing, the Government's Diversion Investigator
testified that only four prescriptions were filled after 4:48 p.m.
Tr. 38; see also RD, at 4. Additionally, the Government only
submitted evidence of four prescriptions that were issued after
Respondent lost his state authority. See RD, at 4.
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Respondent requested a hearing, which was held before DEA
Administrative Law Judge (ALJ) Teresa Wallbaum, who on January 16,
2025, issued her Recommended Rulings, Findings of Fact, Conclusions of
Law, and Decision of the ALJ (RD). The RD recommended that Respondent's
registration be suspended for six months. RD, at 20. Both the
Government and Respondent filed timely Exceptions to the RD.\3\
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\3\ Exceptions are addressed in the Sanction section. See infra
Section III, n.8.
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Having reviewed the entire record, the Agency adopts and hereby
incorporates by reference the ALJ's credibility findings,\4\ findings
of fact, and conclusions of law, and clarifies and expands upon
portions thereof herein. However, the Agency has determined that
revocation is the appropriate sanction based on Respondent's tenuous
acceptance of responsibility and the Agency's interest in deterring
similar acts on the part of other registrants.
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\4\ The Agency adopts the ALJ's summary of the witnesses'
testimonies as well as the ALJ's assessment with respect to each of
the witnesses' credibility. RD, at 5-6.
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II. Applicable Law
As already discussed, the OSC/ISO alleges that Respondent violated
multiple provisions of the Controlled Substances Act (CSA) and its
implementing regulations. As the Supreme Court stated in Gonzales v.
Raich, ``the main objectives of the CSA were to conquer drug abuse and
to control the legitimate and illegitimate traffic in controlled
substances. . . . To effectuate these goals, Congress devised a closed
regulatory system making it unlawful to . . . dispense[ ] or possess
any controlled substance except in a manner authorized by the CSA.''
545 U.S. 1, at 12-13 (2005). In maintaining this closed regulatory
system, ``[t]he CSA and its implementing regulations set forth strict
requirements regarding registration, . . . drug security, and
recordkeeping.'' Id. at 14.
The OSC/ISO's allegations concern the CSA's ``statutory and
regulatory provisions . . . mandating . . . compliance with . . .
prescription requirements'' and, therefore, go to the heart of the
CSA's ``closed regulatory system'' specifically designed ``to conquer
drug abuse and to control the legitimate and illegitimate traffic in
controlled substances,'' and ``to prevent the diversion of drugs from
legitimate to illicit channels.'' Id. at 12-14, 27.
The Allegation That Respondent Issued Prescriptions Outside the Usual
Course of Professional Practice
According to the CSA's implementing regulations, a lawful
prescription for controlled substances is one that is ``issued for a
legitimate medical purpose by an individual practitioner acting in the
usual course of his professional practice.'' 21 CFR 1306.04(a); see
Gonzales v. Oregon, 546 U.S. 243, 274 (2006); United States v. Hayes,
595 F.2d 258 (5th Cir. 1979), rehearing den., 598 F.2d 620 (5th Cir.
1979), cert. denied, 444 U.S. 866 (1979); OSC/ISO, at 2. Under the CSA,
``[a] physician who engages in the unauthorized practice of medicine is
not a `practitioner acting in the usual course of professional
practice.' '' United Prescription Servs., Inc., 72 FR 50397, 50407
(2007) (citing 21 CFR 1306.04(a)); see also Gonzales v. Oregon, 546
U.S. at 270 (``The very definition of a `practitioner' eligible to
prescribe includes physicians `licensed, registered, or otherwise
permitted, by the United States or the jurisdiction in which he
practices' to dispense controlled substances. Sec. 802(21).''); OSC/
ISO, at 2. Moreover, it is unlawful for an individual who is not
licensed to practice medicine in a state to issue a prescription for a
controlled substance. United Prescription Servs., Inc., 72 FR at 50407
(citing 21 CFR 1306.03(a)(1)).\5\
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\5\ The Agency need not adjudicate the criminal violations
alleged in the instant OSC. Ruan v. United States, 597 U.S. 450
(2022) (decided in the context of criminal proceedings).
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In order to lawfully prescribe a controlled substance in Arizona, a
person ``must first . . . [o]btain and possess a current license or
permit as a medical practitioner . . . .'' Ariz. Rev. Stat. Ann. sec.
36-2522(A)(1); see also OSC/ISO, at 1. An individual who is not
``licensed and authorized by law to use and prescribe drugs'' is not a
``medical practitioner.'' Ariz. Rev. Stat. Ann. sec. 32-1901. Arizona
defines the ``unauthorized practice of a health profession'' as
``engag[ing] in the practice of a health profession without having the
licensure or certification required to practice in that health
profession in this state.'' Ariz. Rev. Stat. Ann. sec. 32-3227 (G);
OSC/ISO, at 2.
III. Findings of Fact
The Allegation That Respondent Issued Prescriptions Outside the Usual
Course of Professional Practice
Respondent is a medical doctor in the state of Arizona. RD, at 2.
On April 2024, Respondent entered into a first Interim Consent
Agreement with the Arizona Medical Board (Board), which required
Respondent to comply with certain terms in order to continue practicing
medicine in the State of Arizona. GX 3; see also Tr. at 57-58; RD, at
6. Respondent failed to comply with these terms, and shortly
thereafter, the Board of Arizona offered him a second Interim Consent
Agreement, which prohibited him ``from engaging in the practice of
medicine in the State of Arizona . . . .'' GX 4; see also RD, at 6-7.
Respondent's counsel received a copy of the second Interim Consent
Agreement on June 21, 2024, and Respondent testified that he learned on
June 24, 2024, that he would be restricted from practicing medicine if
he and the Board's Executive signed the Interim Consent Agreement. Tr.
70; see also RD, at 6-7. By its own terms, the Interim Consent
Agreement would become effective ``on the date signed by the Board's
Executive Director.'' GX 4; see also RD, at 4.
Respondent signed the second Interim Consent Agreement on June 26,
2024,
[[Page 19315]]
and emailed the signed agreement to the Board at 3:49 p.m. (MST). GX
13; see also RD, at 6-7. Thereafter, the Board's Executive Director
signed the agreement and emailed the fully-executed version to
Respondent at 4:48 p.m. (MST). GX 14; Tr. 84; see also RD, at 4. The
Agency finds substantial record evidence that Respondent's authority to
prescribe controlled substances in Arizona lapsed on January 26, 2024,
at 4:48 p.m. RD, at 4.
The Agency finds substantial record evidence that after
Respondent's state authority lapsed, Respondent issued four
prescriptions for controlled substances: (1) a prescription for
lorazepam (a schedule IV benzodiazepine), issued to Patient R.B. at
5:53 p.m.; (2) a prescription for morphine (a schedule II opioid),
issued to Patient R.B. at 5:53 p.m.; (3) a prescription for morphine,
issued to Patient D.H. at 5:53 p.m.; and (4) a prescription for
lorazepam, issued to Patient B.T. at 6:23 p.m. GX 6, 11; see also RD,
at 4. At the hearing, Respondent acknowledged that his state authority
had lapsed when he wrote these prescriptions. See Transcript (Tr.) at
84; RD, at 10-11; see also Respondent's Post-Hearing Brief, at 1-2.\6\
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\6\ Under the Proposed Findings of Fact, Respondent admitted
that he ``entered into an Interim Consent Agreement for Practice
Restriction . . . with the Arizona Medical Board.'' Respondent's
Post-Hearing Brief, at 1. Respondent also indicated that ``[t]he
Interim Consent Agreement for Practice Restriction became effective
on the date it was signed by the Arizona Medical Board's Executive
Director, which was June 26, 2024.'' Id. at 2. Moreover, Respondent
admitted that he issued four prescriptions after 4:48 p.m.,
(specifically between 5:53 p.m. and 6:23 p.m.). Id., at 2.
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Accordingly, the Agency finds substantial record evidence that
Respondent issued four prescriptions for controlled substances without
possessing the requisite state authority to prescribe controlled
substances in the State of Arizona.
IV. Discussion
A. The Five Public Interest Factors
Under Section 304 of the CSA, ``[a] registration . . . to . . .
distribute[ ] or dispense a controlled substance . . . may be suspended
or revoked by the Attorney General upon a finding that the registrant .
. . has committed such acts as would render his registration under . .
. [21 U.S.C. 823] inconsistent with the public interest as determined
by such section.'' 21 U.S.C. 824(a)(4). In the case of a
``practitioner,'' Congress directed the Attorney General to consider
five factors in making the public interest determination. 21 U.S.C.
823(g)(1)(A-E).\7\ The five factors are considered in the disjunctive.
Gonzales v. Oregon, 546 U.S. 243, 292-93 (2006) (Scalia, J.,
dissenting) (``It is well established that these factors are to be
considered in the disjunctive,'' citing In re Arora, 60 FR 4447, 4448
(1995)); Robert A. Leslie, M.D., 68 FR 15227, 15230 (2003). Each factor
is weighed on a case-by-case basis. Morall v. Drug Enf't Admin., 412
F.3d 165, 173-74 (D.C. Cir. 2005). Any one factor, or combination of
factors, may be decisive. Penick Corp. v. Drug Enf't Admin., 491 F.3d
483, 490 (D.C. Cir. 2007); Morall, 412 F.3d. at 185 n.2; David H.
Gillis, M.D., 58 FR 37507, 37508 (1993).
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\7\ The five factors of 21 U.S.C. 823(g)(1)(A-E) are:
(A) The recommendation of the appropriate State licensing board
or professional disciplinary authority.
(B) The [registrant's] experience in dispensing, or conducting
research with respect to controlled substances.
(C) The [registrant's] conviction record under Federal or State
laws relating to the manufacture, distribution, or dispensing of
controlled substances.
(D) Compliance with applicable State, Federal, or local laws
relating to controlled substances.
(E) Such other conduct which may threaten the public health and
safety.
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In this matter, while all of the 21 U.S.C. 823(g)(1) factors have
been considered, the Agency finds that the Government's evidence in
support of its prima facie case is confined to Factors B and D. See RD,
at 11. Moreover, the Government has the burden of proof in this
proceeding. 21 CFR 1301.44. The Agency agrees with the ALJ and finds
that the Government's evidence satisfies its prima facie burden of
showing that Respondent's registration would be ``inconsistent with the
public interest.'' 21 U.S.C. 823(g)(1); RD, at 11.
B. Allegation That Respondent's Registration Is Inconsistent With the
Public Interest
Factors B and/or D--Respondent Experience in Dispensing Controlled
Substances and Compliance With Applicable Laws Related to Controlled
Substances
Evidence is considered under Public Interest Factors B and D when
it reflects compliance or non-compliance with federal and local laws
related to controlled substances and experience dispensing controlled
substances. 21 U.S.C. 823(g)(1)(B) and (D); see also Kareem Hubbard,
M.D., 87 FR 21156, 21162 (2022). Here, as found above, the Agency
agrees with the ALJ and finds that substantial record evidence that
Respondent issued four prescriptions for controlled substances without
possessing the requisite state authority to prescribe controlled
substances in the State of Arizona in violation of Ariz. Rev. Stat.
Ann. secs. 36-2522(A). Accordingly, the Agency finds substantial record
evidence that these prescriptions were issued outside the usual course
of professional practice and violated federal and state laws, namely 21
CFR 1306.4(a), and Ariz. Rev. Stat. Ann. secs. 36-2522(A).
The Agency finds that Factors B and D weigh in favor of revocation
of Respondent's registration and that Respondent's continued
registration would be inconsistent with the public interest in
balancing the factors of 21 U.S.C. 823(g)(1). Accordingly, the Agency
finds that the Government established a prima facie case, that
Respondent did not rebut that prima facie case, and that there is
substantial record evidence supporting the revocation of Respondent's
registration. 21 U.S.C. 823(g)(1).
III. Sanction
Where, as here, the Government has met its prima facie burden of
Respondent's registration is inconsistent with the public interest due
to its numerous violations pertaining to controlled substances, the
burden shifts to Respondent to show why he can be entrusted with a
registration. Jones Total Health Care Pharmacy., 881 F.3d 823, 830
(11th Cir. 2018); Morall, 412 F.3d at 174; Garrett Howard Smith, M.D.,
83 FR 18882, 18904 (2018). The issue of trust is necessarily a fact-
dependent determination based on the circumstances presented by the
individual respondent. Jeffrey Stein, M.D., 84 FR 46968, 46972 (2019);
see also Jones Total Health Care Pharmacy, 881 F.3d at 833. Moreover,
as past performance is the best predictor of future performance, DEA
Administrators have required that a registrant who has committed acts
inconsistent with the public interest must accept responsibility for
those acts and demonstrate that it will not engage in future
misconduct. Jones Total Health Care Pharmacy, 881 F.3d at 833; ALRA
Labs, Inc. v. Drug Enf't Admin., 54 F.3d 450, 452 (7th Cir. 1995). A
registrant's acceptance of responsibility must be unequivocal. Jones
Total Health Care Pharmacy, 881 F.3d at 830-31. In addition, a
registrant's candor during the investigation and hearing has been an
important factor in determining acceptance of responsibility and the
appropriate sanction. Id. Further, the Agency has found that the
egregiousness and extent of the misconduct are significant factors in
determining the appropriate sanction. Id. at 834 & n.4. The Agency has
also considered the need to deter similar acts by the
[[Page 19316]]
respondent and by the community of registrants. Jeffrey Stein, M.D., 84
FR at 46972-73.
A. Acceptance of Responsibility
The Agency agrees with the ALJ that there is substantial record
evidence that Respondent failed to unequivocally accept responsibility
for his misconduct. RD, at 15. When given several opportunities to
accept responsibility at the hearing, Respondent failed to precisely
articulate what he did wrong. See Respondent's Post-Hearing Brief, at
5; Tr. 77; RD, at 13. For example, Respondent did not acknowledge that
he engaged in unprofessional conduct by violating the consent
agreement; instead, he testified that he ``was too busy to check [his]
email.'' Tr. 88; see also RD, at 13-14. Respondent also testified that
if given another chance to correct his misconduct, the only adjustment
he would have made was to check his email before issuing the
prescriptions. Tr. 77; see also RD, at 15. Furthermore, in response to
the ALJ's question as to why he neglected to check his email prior to
prescribing the controlled substances, Respondent answered that he was
working to complete his medical duties, such as ``documentation and . .
. communicating with [his] nursing staff.'' Tr. 87; see also RD, at 15.
Significantly, Respondent never admitted that he violated the CSA by
prescribing two Schedule II opioids and two Schedule IV benzodiazepine
after he had signed the agreement. See RD, at 16-19.
Moreover, when the ALJ asked about his commitment to prevent future
diversion of controlled substances, Respondent failed to offer concrete
solutions, such as ensuring that he would transition his medical duties
prior to losing his state authority. Tr. at 79-80; see RD, 12-15.
Instead, Respondent detracted from his acceptance of responsibility by
focusing his testimony on when, technically, he lost authority to
prescribe medication. He testified that he ``knew that the restriction
took effect not when [he] signed [the agreement] but when the executive
director of the Medical Board signed it.'' Tr. 87; see RD, at 13.
Respondent also attempted to excuse his misconduct by highlighting the
shortage of medical professionals in his community and implying that he
had no choice but to issue the prescriptions. Tr. 81-82; see also RD,
at 15
Respondent's attempts at the hearing to minimize, justify, and
excuse his misconduct detract from his acceptance of responsibility and
show that he lacked an understanding of the gravity of his misconduct.
See Tr. 77; RD, at 12-14.\8\ See Jones Total Health Care Pharmacy, LLC,
881 F.3d at 833 (finding that ``it was reasonable for the agency to
conclude that [respondent's] failure to clearly acknowledge even
unintentional misconduct demonstrated lack of understanding of her
legal obligations'').
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\8\ Respondent filed an Exception to the RD and emphasized that
he ``accepted responsibility for his actions and explained what
actions he should have taken.'' Respondent's Exception to the
Recommended Decision of the Administrative Law, at 2 (citing to Tr.
77). Respondent argued that the ALJ misconstrued his explanations of
his misconduct as undermining his acceptance of responsibility, when
in fact they were meant to provide context for the tribunal in
interpreting his actions. Id. The Agency agrees with the ALJ's
analysis of Respondent's testimony and agrees that Respondent made
many statements that undermined his acceptance of responsibility.
The Agency ``has long considered statements that are aimed at
minimizing the egregiousness of its conduct to weigh against a
finding of acceptance of full responsibility.'' Medical Pharmacy, 86
FR 72030, 72054 (2021); see also Michael A. White v. Drug Enf't
Admin., 626 F. App'x 493, 496-97 (5th Cir. 2015). Moreover, the
Agency has long noted that ``the degree of acceptance of
responsibility that is required does not hinge on the respondent
uttering `magic words' of repentance, but rather on whether the
respondent has credibly and candidly demonstrated that he will not
repeat the same behavior and endanger the public in a manner that
instills confidence in the Administrator.'' Jeffrey Stein, M.D., 84
FR 46968, 46973 (2019). Here, Respondent has not met his burden.
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Regarding these matters, there is no record evidence that
Respondent takes responsibility, let alone unequivocal responsibility,
for the founded violations. Accordingly, Respondent did not convince
the Agency that he would comply with the legal requirements of the CSA
in the future or that he can be entrusted with a registration.
B. Deterrence and Egregiousness
In addition to unequivocally accepting responsibility, the Agency
considers both specific and general deterrence when determining an
appropriate sanction. Daniel A. Glick, 80 FR 74800, 74810 (2015). In
this case, the Agency agrees with the ALJ and finds substantial
evidence that ``it must impose a sanction on Respondent to impress upon
him that he cannot be negligent in such important matters.'' RD, at 19.
Respondent was aware that he had signed a legal agreement that
restricted his medical practice but failed to adhere to the terms of
the agreement. Id., at 19.
The Agency further agrees with the ALJ that the interests of
general deterrence compel a similar result. RD, at 18. As the ALJ
states, ``this tribunal must craft a sanction that sends a message to
all registrants that the Agency takes such conduct seriously.'' Id., at
18. If the Agency permitted Respondent to retain his registration, it
would signal that registrants may be negligent or inattentive to
contractual terms and laws that restrict their medical practice, even
when those rules are crucial to preventing the abuse and diversion of
dangerous controlled substances.\9\ Prescribing controlled substances
without state authority is an
[[Page 19317]]
egregious violation of the CSA and an act of diversion.
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\9\ The ALJ concluded that Respondent's conduct was egregious,
but found that this was an ``unusual case, with narrow facts.'' RD,
at 16. Because Respondent issued the prescriptions within ninety
minutes of the practice restriction, the ALJ suspended Respondent's
registration for six months instead of revoking his registration.
Id., at 19.
In his Post-Hearing Brief, Respondent argued, in part, that his
misconduct was not egregious because it was not intentional.
Respondent's Post-Hearing Brief, at 7 (citing Paul J. Caragine, 63
FR 51592, 51602 (1998). But in Caragine, the Agency was clear that
misconduct need not be intentional to revoke a registrant's
registration: ``[j]ust because misconduct is unintentional, innocent
or devoid of improper motivation, does not preclude revocation or
denial.'' Id. at 51601. Indeed, the Agency emphasized that
``[c]areless or negligent handling of controlled substances create
the opportunity for diversion and could justify revocation or
denial.'' Id.; see also RD, at 17 (``Agency precedent has
consistently held that even unintentional misconduct can nonetheless
create a substantial risk of diversion and be egregious.'') (citing
Paul J. Caragine, Jr., 63 FR at 51601) (other citations omitted).
The Government argued in its Exceptions that ``the overall
egregiousness of Respondent's conduct'' warrants a revocation.
Government's Exception to the RD, at 3. Here, they argue, Respondent
violated the CSA and committed an act of diversion when he
unlawfully prescribed controlled substances without state authority.
See 21 CFR 1306.04(a).
In general, the Agency believes that prescribing controlled
substances without state authority is an egregious act. However, the
Agency is not required to find that a registrant's misconduct is
egregious before revoking a registration where, as here, the
registrant has failed to accept responsibility. Cf. Jones Total
Health Care Pharmacy, 881 F.3d at 833 (rejecting respondent's
argument that its conduct was not egregious enough to warrant a
sanction of revocation and highlighting the Agency's historical
focus on acceptance of responsibility: ``The DEA decisions
Petitioners rely on are distinguishable because, in each of the
decisions, the agency found that the registrant had rebutted the
government's case by, among other things, admitting fault or
expressing remorse. . . . Petitioners . . . do not cite any decision
in which the DEA has continued a registration despite finding that
the registrant did not fully accept responsibility''); MacKay v.
Drug Enf't Admin., 664 F.3d 808, 822 (10th Cir. 2011) (finding that
``because [the respondent] ha[d] not accepted responsibility for his
conduct, revocation of his registration [was] entirely consistent
with DEA policy''); Jeffery J. Becker, D.D.S., 77 FR 72387, 72408
(2012) (``Agency precedent has firmly placed acknowledgement of
guilt and acceptance of responsibility as conditions precedent to
merit the granting or continuation of status as a registrant.'');
Jayam Krishna-Iyer, M.D., 74 FR 459, 464 (2009) (``even where the
Agency's proof establishes that a practitioner has committed only a
few acts of diversion, this Agency will not grant or continue the
practitioner's registration unless he accepts responsibility for his
misconduct''). Here, Respondent's failure to unequivocally accept
responsibility demonstrated that the Agency cannot trust him to
responsibly handle controlled substances.
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In sum, Respondent has not offered sufficient credible evidence on
the record to rebut the Government's case for revocation, and
Respondent has not demonstrated that he can be entrusted with the
responsibility of registration. Accordingly, the Agency will order that
Respondent's registration be revoked.
Order
Pursuant to 28 CFR. 0.100(b) and the authority vested in me by 21
U.S.C. 824(a) and 21 U.S.C. 823(g)(1), I hereby revoke DEA Certificate
of Registration No. FD 3660304 issued to Peter Dashkoff, M.D. Further,
pursuant to 28 CFR 0.100(b) and the authority vested in me by 21 U.S.C.
824(a) and 21 U.S.C. 823(g)(1), I hereby deny any pending applications
of Peter Dashkoff, M.D., to renew or modify this registration, as well
as any other pending application of Peter Dashkoff, M.D., for
additional registration in the state of Arizona. This Order is
effective June 6, 2025.
Signing Authority
This document of the Drug Enforcement Administration was signed on
May 1, 2025, by Acting Administrator Derek Maltz. That document with
the original signature and date is maintained by DEA. For
administrative purposes only, and in compliance with requirements of
the Office of the Federal Register, the undersigned DEA Federal
Register Liaison Officer has been authorized to sign and submit the
document in electronic format for publication, as an official document
of DEA. This administrative process in no way alters the legal effect
of this document upon publication in the Federal Register.
Heather Achbach,
Federal Register Liaison Officer, Drug Enforcement Administration.
[FR Doc. 2025-07933 Filed 5-6-25; 8:45 am]
BILLING CODE 4410-09-P