By Grace Inc. Counseling Services; Decision and Order

Document Headings Document headings vary by document type but may contain the following: the agency or agencies that issued and signed a document the number of the CFR title and the number of each part the document amends, proposes to amend, or is directly related to the agency docket number / agency internal file number the RIN which identifies each regulatory action listed in the Unified Agenda of Federal Regulatory and Deregulatory Actions See the Document Drafting Handbook for more details. Department of Justice Drug Enforcement Administration I. Introduction On October 29, 2024, the Drug Enforcement Administration (DEA or Government) issued an Order to Show Cause (OSC) to By Grace Inc. Counseling Services of Baltimore, Maryland (Respondent). OSC, at 1. The OSC proposed the revocation of Respondent's DEA registration, No. RB0369733, alleging that Respondent, a narcotic treatment program (NTP), “demonstrated a lack of effective controls and procedures to guard against the diversion of controlled substances” and committed numerous recordkeeping violations that rendered DEA unable to determine an accurate and complete inventory of the controlled substances on hand. Id. at 2-4 (citing 21 U.S.C. 823(g) ; 21 U.S.C. 824(a) ;  [ 1 ] 21 CFR 1304.11(a)-(c) , 1304.11(c) , 1304.21(a) , (d) , 1304.04(a) , (f)(2) , 1304.24(a) , 1305.05 ). The Government additionally alleged in its Prehearing Statement that Respondent materially falsified its application for a DEA registration by falsely responding “no” to Liability Question 4—which asks whether any officer of the corporation has ever been convicted of a crime in connection with controlled substances—and by failing to disclose that its owner was convicted of unlawful possession of controlled substances in Maryland. Administrative Law Judge Exhibit (ALJX) 6, at 2-3. [ 2 ] After conducting a hearing, Administrative Law Judge Paul E. Soeffing (ALJ) issued his Recommended Rulings, Finding…