Brightside Coworking Updates Facility Services to Support DEA Registration for Oregon-Licensed Telehealth Prescribers
When multiple Oregon-licensed telehealth prescribers reached out to Brightside Coworking looking for a physical base of operations, we noticed a trend: remote providers are struggling to find affordable and appropriate office space solutions to meet DEA Diversion Control registration requirements. To protect our current members and support incoming practitioners, we reached out directly to the DEA Oregon field office and Senator Ron Wyden’s team. Here’s what we uncovered about the intersection of coworking, USPS mail regulations, and DEA compliance—and how we’ve responded to enhance our services.
Note: This blog post addresses a variety of legal and regulatory topics and reflects Brightside’s operational understanding of those regulations and how they inform our commercial services as of the date this post was published. This is not legal advice, and we recommend that any reader seeking formal legal guidance on these topics consult with a qualified attorney.
Legislative and Regulatory Background
Regulations for telehealth prescribers are authorized by the Ryan Haight Online Pharmacy Consumer Protection Act of 2008, which is an amendment of the Controlled Substances Act. The Ryan Haight Act states that telehealth prescribers of controlled substances must conduct at least one in-person medical evaluation of the patient prior to prescribing and authorizes the DEA and HHS to establish regulations related to telehealth prescribing, while allowing the DEA to implement exceptions under certain conditions. During the COVID lockdown, the DEA suspended requirements for the initial in-person evaluation. This temporary suspension has been renewed continuously since then; the current extension of that suspension expires on December 31, 2026.
While the in-person evaluation requirement is suspended, this suspension does not apply to requirements for telehealth prescribers to satisfy facility requirements within states where they are licensed and provide services to patients. DEA Form 224 collects information required for registration with the DEA diversion control program for practitioners. Brightside has several existing members who have used our facilities as their base of operations within Oregon and successfully completed the registration process. Yet, some members have also experienced challenges with the registration process related to our facilities, causing us to take a deeper dive into facility requirements for this audience.
Background on Our Research
In June 2026, working through Senator Ron Wyden’s office, we asked about issues in one case. Through Senator Wyden’s office, we were able to connect with professionals at the DEA Oregon field office and described our understanding of facility requirements and the services that we planned to implement for telehealth prescribers to meet these requirements. Their response was concise – thank you for sharing your plans, you can continue to provide services to telehealth prescribers, and we have no further comments.
Because the DEA staff were not willing to directly comment on our services or questions about facility requirements, we were left with some uncertainty about how to verify that these service plans conform to requirements, or if there are any gaps in our services. As we’ve noted before, we do have members who have successfully registered with the DEA using our facilities, and this is prior to undertaking this inquiry. Interested parties should consider our services as being adopted based on prospective concerns, rather than being based on confirmed requirements. As Brightside learns more about requirements, we will continue to adapt to serving this community.
More about the Telemedicine Prescribing Waivers
While the DEA’s temporary waiver, officially known as the COVID-19 Telemedicine Flexibilities for Prescription of Controlled Medications, may initially have been intended as a temporary measure, there is formal indication that these flexibilities will continue. Sequential extensions are designed to buy time for revised rulemaking that permanently adapts the in-person evaluation requirement of the Ryan Haight Act. To that end, the DEA published a Notice of Proposed Rulemaking (NPRM) for Special Registrations for Telemedicine. Once finalized, this rule is expected to create a permanent regulatory pathway allowing qualified practitioners to prescribe Schedule II-V controlled substances without an initial in-person medical evaluation.
State of Oregon Regulations Related to Telehealth Prescribers
In addition to satisfying DEA diversion control registration requirements, telehealth prescribers must familiarize themselves with State of Oregon regulations for prescribing controlled substances. The Oregon Medical Board (OMB) issues different license classifications based on location. While the OMB allows out-of-state physicians to hold a "Telemedicine Status" license if they practice entirely outside the state, providers holding a standard "Active Status" license are legally required to maintain a physical practice address within the state of Oregon.
Furthermore, Oregon requires that any practitioner with an active DEA registration authorized to prescribe in Oregon must also register with the Oregon Prescription Drug Monitoring Program (PDMP) within 30 days of receiving that state license or DEA number. Oregon PDMP compiles data from retail pharmacies regarding dispensed Scheduled II-IV controlled substances, as well as gabapentin and naloxone. Oregon regulations include Mandatory checks and documentation of the PDMP to deter diversion and over-prescribing.
Our Solutions to Five DEA Facility Requirements
Brightside Coworking’s analysis suggests that there are five critical facility requirements that members must address, and we have implemented solutions for each of these requirements on a going forward basis.
SITE ACCESS: DEA investigators must have access for unannounced site inspections.
Brightside Solution: We have posted staff contact information at each of our suite entrances when providers are not present.
VERIFICATION OF OCCUPANCY: DEA investigators must verify the diversion control applicant is an occupant during their inspection.
Brightside Solution: Brightside Coworking has deployed Digital Directories in our lobbies. Members can create a directory entry including photos, names, contact information, and a summary of their practice. Our full member directory is posted on our website.
FIXED, SECURE, DEDICATED LOCATION: DEA may expect each telehealth prescriber to have a fixed, secure, and dedicated location on site.
Brightside Solution: We have implemented an individual locker rental program to give telehealth prescribers a dedicated, secure storage location.
DEA REGISTRATION DISPLAY: DEA inspectors may look for completed Form 223 Certificate of Registration documents.
Brightside Solution: Brightside is initiating efforts to collect these documents and store them securely on-site at each facility to support investigators.
CONTRACTUAL AGREEMENT: Members must submit a compliant service agreement with Form 224.
Brightside Solution: We updated our standard member agreement to clarify that Mail Service members are authorized to reserve office space, explicitly prohibit the storage/dispensing of controlled substances, and outline locker provisions.
Conflicting Regulations between USPS and DEA
A recent key challenge related to DEA registration has its origin in conflicting policy and regulations between the United States Postal Service (USPS) and the Drug Enforcement Agency (DEA).
In 2024 the USPS revised and expanded a long-standing policy that governs Commercial Mail Receiving Agencies (CMRAs). CMRAs are businesses that receive mail on behalf of commercial clients in a single mail receiving receptacle and then distribute that mail to their clients. Traditionally, businesses like Postal Annex and UPS Stores were covered by this regulation. The USPS requires that CMRAs register with the USPS, and that all individuals or businesses using these services must also submit paperwork that verifies their identity and authorizes the CMRA to receive mail on their behalf.
In 2024, the scope of the CMRA regulation was expanded to include all entities that receive mail on commercial customers’ behalf in cases where USPS is not delivering directly to a secure receptacle assigned to the mail recipient. This scope change means that among other entities, Coworking Offices that are receiving mail on behalf of members had to register as CMRAs.
The conflict in regulation arises because the DEA has traditionally viewed CMRAs as “Mailstop only” locations. The DEA is informed regarding CMRA designated locations, and we are aware that in some cases DEA investigators have raised objections to Form 224 applicants for listing a facility that is identified as a CMRA. Three of Brightside Coworking’s locations are registered as CMRAs, elevating this potential risk.
To mitigate the concern, Brightside Coworking has communicated with DEA investigators in Oregon to identify all our facility addresses, and to communicate clearly that we are not a mailstop only location and simply are required to comply with this USPS regulation. The DEA has acknowledged receipt of this communication.
Open Questions
Because the DEA will not comment on specific commercial services, Brightside is left with some unanswered questions related to our services. While we assess the services we are offering are appropriate, we don’t really know if they are all necessary or if they are sufficient. To that end, we depend on member feedback on their DEA registration experiences to help refine our understanding of needs for telehealth prescribers.
One area of uncertainty related to our Mailbox program. We know from member feedback that the DEA will not accept a “mailstop only” location as an acceptable facility for diversion control registration. The precipitating incident that led to our deeper dive on this topic is directly related to this concern. Brightside views the use of our mailbox service as a basis for DEA division control registration as a gray area. On the one hand, our mailbox program allows subscribers to make office reservations on an as-needed basis. On the other hand, DEA investigators may assess that this is insufficient.
We know that some of our DEA registered members are currently enrolled in the mailbox only program. But in at least one instance, the provider in question downgraded to this mailbox program after successfully completing their registration process. We are not aware of anyone successfully completing the registration process with a mailbox only subscription, but there are currently members applications in process using the program so we’re likely to learn more soon.
Find Out More
Brightside Coworking is a coworking office space designed specifically to support therapists and their clients. All our offices have secure facilities, offering unattended reception areas and private offices suitable for confidential care. Our services are restricted to licensed professionals.
If you’re a telehealth prescriber licensed in Oregon and looking for a suitable facility to support your DEA diversion control registration, we invite you to take a deeper look at Brightside Facilities and Services.
· Explore Plans & Rates: View our transparent pricing on our Services Page.
· See Our Spaces: Take a virtual tour of our locations from our Locations Page.
· Get Started: Contact Brightside to get ask questions and start today.
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