The Drug Enforcement Administration (DEA) has revoked the controlled substance registrations of Chantal F. Nouvellon, D.O., a physician previously registered in Massachusetts and New Hampshire. This decision, published in the Federal Register on October 20, 2025, follows the suspension of her state medical licenses in both jurisdictions. The revocation underscores a core principle of federal drug enforcement: practitioners must maintain state authority to handle controlled substances. Issued under the authority of DEA Administrator Terrance Cole, the order takes effect on November 19, 2025, and also denies any pending applications for renewal or modification. This development affects Nouvellon's ability to prescribe or dispense controlled substances, reflecting broader regulatory efforts to ensure compliance with state and federal laws.
Background on the Case
Dr. Chantal F. Nouvellon held DEA Certificates of Registration Nos. BN5595775 and FN5439016, which allowed her to handle controlled substances in Massachusetts and New Hampshire, respectively. According to the Federal Register notice, her Massachusetts medical license was suspended on or about October 17, 2024, followed by the suspension of her New Hampshire license on December 20, 2024. Online records from the Massachusetts Board of Registration in Medicine and the New Hampshire Online Licensing Person Search confirm these suspensions remain in effect as of the order's signature date.
The DEA initiated proceedings on April 2, 2025, by issuing an Order to Show Cause (OSC) to Nouvellon. The OSC alleged that she lacked authority to handle controlled substances in the states where she was registered, citing 21 U.S.C. 824(a)(3). This statute authorizes the revocation of DEA registrations when a practitioner's state license is suspended or revoked. Nouvellon did not request a hearing, leading to a default judgment where she was deemed to have admitted the OSC's factual allegations.
Service of the OSC involved multiple attempts, including personal delivery efforts and communications through her attorney and directly via email. A DEA Diversion Investigator's declaration details these steps, noting Nouvellon's response that she was not prescribing due to her suspension but providing no further engagement.
Legal Basis for Revocation
The DEA's action rests on established federal law and precedents that link state licensing to federal registration. Under 21 U.S.C. 823(g)(1), the Attorney General registers practitioners only if they are authorized to dispense controlled substances under state law. The Controlled Substances Act defines a "practitioner" as someone licensed by their jurisdiction to distribute or dispense such substances in professional practice (21 U.S.C. 802(21)).
State laws in Massachusetts and New Hampshire reinforce this requirement. In Massachusetts, "dispense" means delivering controlled substances to patients by a licensed practitioner (Mass. Gen. Laws ch. 94C, Sec. 1). Similarly, New Hampshire defines "dispense" as distributing or selling doses and requires practitioners to be licensed for such activities (N.H. Rev. Stat. Ann. Sec. 318-B:1).
DEA precedents consistently uphold revocation in cases of lost state authority. For instance, in James L. Hooper, M.D. (76 FR 71371, 2011), the agency revoked a registration after a state license suspension, a decision affirmed by the Fourth Circuit. Earlier cases like Frederick Marsh Blanton, M.D. (43 FR 27616, 1978) established that state authorization is fundamental to maintaining DEA registration. The U.S. Supreme Court in Gonzales v. Oregon (546 U.S. 243, 2006) affirmed that federal registration depends on state licensing.
Procedural History and Key Players
The process began with the state suspensions, prompting DEA action. Key players include Nouvellon, the DEA's Diversion Investigator who handled service, and her attorney who initially accepted the OSC but clarified non-representation in the administrative matter.
Without a hearing request, the case proceeded to a request for final agency action under 21 CFR 1301.43 and 1316.67. The Administrator, drawing authority from 21 U.S.C. 824(a) and 28 CFR 0.100(b), issued the revocation. The notice allows Nouvellon 15 days to file a motion for reconsideration if she disputes the findings on her license status, per 5 U.S.C. 556(e).
This default-based revocation highlights procedural efficiencies in DEA enforcement, where non-response leads to admission of allegations. Perspectives vary: proponents see it as essential for public safety, while critics argue it may limit due process for practitioners facing state-level issues.
Implications and Perspectives
The revocation has immediate effects on Nouvellon's practice, barring her from handling controlled substances in Massachusetts and New Hampshire until state licenses are restored. Short-term implications include potential disruptions to patient care if she had an active practice, though the notice indicates she was not prescribing post-suspension.
Longer-term, this case illustrates the DEA's role in enforcing the nexus between state and federal authority. It may influence how states handle license suspensions, knowing federal consequences follow. From a policy viewpoint, supporters of strict enforcement argue it prevents unauthorized drug distribution, aligning with efforts to combat opioid misuse. Conversely, medical associations sometimes advocate for more nuanced approaches, suggesting that temporary suspensions should not automatically trigger federal revocation without considering underlying reasons.
Broader political forces include ongoing debates over federal versus state oversight in healthcare. The DEA's actions here reflect a consistent application of the Controlled Substances Act, unchanged across administrations.
In summary, the DEA's revocation of Dr. Chantal F. Nouvellon's registrations enforces the requirement for state licensing to maintain federal authority over controlled substances. Potential next steps could involve Nouvellon seeking reinstatement of her state licenses, which might allow for new DEA applications. Ongoing debates may focus on balancing regulatory enforcement with practitioner rights, particularly in cases of default judgments. Challenges include ensuring fair service of process and opportunities for rebuttal, as seen in the detailed service record here. Future trajectories could see similar cases prompting calls for procedural reforms or increased coordination between state boards and federal agencies.