In the Matter of Kevin Dennis, M.D. (August 26, 2013) In 2007, Dr. Kevin Dennis became involved with an Internet prescribing company known as “Telemed Ventures.” Between 2007 and 2008, Dr. Dennis (who was licensed and registered in Tennessee only) issued numerous prescriptions to individuals located in other states without seeing them or performing any kind of physical examination of them. He also prescribed phentermine, a Schedule IV controlled substance, to members of his immediate family. On April 12, 2011, DEA issued an Order to Show Cause proposing the revocation of Dr. Dennis’ DEA registration. After reviewing the record, the Administrator found that while working as a Telemed Ventures physician, Dr. Dennis had issued many controlled substance prescriptions lacking a legitimate medical purpose, and that he had acted outside the usual course of his professional practice. This conclusion was supported by the Administrator’s finding that Dr. Dennis issued prescriptions for controlled substances to individuals in Mississippi, North Carolina, and South Carolina without performing a physical examination of them, and without being licensed to practice medicine in those states. The Administrator also found that Dr. Dennis violated Tennessee law when he issued prescriptions for phentermine to members of his immediate family. Throughout the administrative process, Dr. Dennis maintained that Telemed Ventures had used his DEA registration to issue these out-of-state prescriptions without his knowledge or authority. Dr. Dennis claimed that he did not become aware of the out-of-state prescriptions until around April 2008. Ultimately (and in disagreement with the Administrative Law Judge), the Administrator placed no stock in Dr. Dennis’ version of the story, finding it to be “inherently implausible.” The Administrator did, however, note that the outcome of the case would not have changed even if she believed Dr. Dennis’ version of the facts. Her reasoning was twofold: first, because Dr. Dennis entrusted his DEA registration information to Telemed Ventures, he was still liable for all the prescriptions the company issued under his registration. And second, after becoming aware of the problem, Dr. Dennis facilitated additional acts of diversion by failing to report the unlawful use of his DEA registration to the Agency (additional out-of-state prescriptions for controlled substances were issued under Dr. Dennis’ DEA registration after April 2008). All told, Dr. Dennis’ past misconduct implicated factors two (experience in dispensing controlled substances), four (compliance with federal and state law relating to controlled substances), and five (other conduct which may threaten public health and safety). Finally, the Administrator found that Dr. Dennis failed to accept responsibility for his past misconduct, had not rebutted the Government’s case, and she ordered the revocation of his registration.