1

Proposed New Registrant Fee Schedule Calculations

Diversion Control Fee Account

By

Drug Enforcement Administration

Office of Diversion Control

Diversion Planning and Resource Section

February 1, 2011
Proposed New Registrant Fee Schedule Calculations 2/1/2011

2

Table of Contents

1 INTRODUCTION ............................................................................................................................................3

2 OVERVIEW OF REGISTRANT FEE CALCULATION METHODOLOGY ..................................................................5

3 PROPOSED FEE CALCULATION ......................................................................................................................7

3.1 BUDGET: FY 2012-FY 2014................................................................................................................................7

3.1.1 Definition ...............................................................................................................................................7

3.1.2 FY 2012 ..................................................................................................................................................8

3.1.3 FY 2013 Estimate .................................................................................................................................10

3.1.4 FY 2014 Estimate .................................................................................................................................12

3.1.5 FY 2012-FY 2014 Summary ..................................................................................................................13

3.2 REQUIRED COLLECTIONS FROM REGISTRATION FEES..................................................................................................13

3.2.1 Payment to Treasury............................................................................................................................14

3.2.2 Operational Continuity Fund (OCF)......................................................................................................14

3.2.3 Combat Methamphetamine Epidemic Act of 2005 (CMEA) Collections ..............................................14

3.2.4 Other Collections..................................................................................................................................15

3.2.5 Recoveries from Money Not Spent as Planned (Deobligation of Prior Year Obligations) ....................15

3.2.6 Summary..............................................................................................................................................15

3.3 ESTIMATED NUMBER OF REGISTRATION FEE TRANSACTIONS: FY 2012 – F 2014...........................................................16

3.4 PROPOSED REGISTRATION FEES BY BUSINESS ACTIVITY ..............................................................................................17

3.5 ESTIMATED COLLECTIONS FROM REGISTRATION FEES ................................................................................................18

4 SUMMARY OF RESULTS .............................................................................................................................. 19

5 FACTORS THAT CAN INFLUENCE ACTUAL RESULTS...................................................................................... 21

APPENDIX 1: LIST OF ACRONYMS........................................................................................................................ 22

APPENDIX 2: ASSUMPTIONS ON STAFFING LEVELS FOR THE PURPOSES OF CALCULATING DCP COST FOR 

REGISTRATION FEES............................................................................................................................................. 23

APPENDIX 3: MODULAR COSTS........................................................................................................................... 24

APPENDIX 4: STAFFING PLAN IMPLEMENTATION COST ...................................................................................... 31

APPENDIX 5: TARGET OPERATIONAL CONTINUITY FUND.................................................................................... 34

APPENDIX 6: ESTIMATED NUMBER OF REGISTRATION FEE TRANSACTIONS........................................................ 37

APPENDIX 7: COLLECTIONS ESTIMATES BASED ON PROPOSED FEE ..................................................................... 42
Proposed New Registrant Fee Schedule Calculations 2/1/2011

3

1 Introduction

Under the Controlled Substances Act (CSA), the Drug Enforcement Administration (DEA) is 

authorized to charge reasonable fees relating to the registration and control of the manufacture, 

distribution, dispensing, import, and export of controlled substances and listed chemicals. 21 

U.S.C. 821 and 958(f). DEA must set fees at a level that ensures the recovery of the full costs of 

operating the various aspects of its Diversion Control Program (DCP). 21 U.S.C. 886a(1)(C). 

Fee revenues are deposited into a separate fund of the Treasury called the Diversion Control Fee 

Account (DCFA). 21 U.S.C. 886a. 

DEA continually monitors the anticipated budget and collections to determine whether the 

registration fees need to be adjusted. DEA has determined that the fees need to increase in Fiscal 

Year (FY) 2012, beginning October 1, 2011, to the amounts indicated in Table 1: Proposed

Registration and Reregistration Fees in order to fully fund the DCP as required by statute.

Table 1: Proposed Registration and Reregistration Fees

Registrants on Three Year Registration Cycle

Registrant Class/Business Current 

Three Year

Fee*

Proposed

Three Year

Fee*

Difference

Per Year

Pharmacy $551 $732 $60

Hospital/Clinic $551 $732 $60

Practitioner $551 $732 $60

Teaching Institution $551 $732 $60

Mid-Level Practitioner $551 $732 $60

*Pharmacies, hospitals/clinics, practitioners, teaching institutions, and mid-level practitioners currently pay a fee for a 

three-year period. This current three-year fee is $551. The proposed new fee for the three year registration period 

would be $732. The three year difference is $181 or an annual difference of $60.

Registrants on Annual Registration Cycle

Registrant Class/Business Current 

Annual Fee

Proposed 

Annual Fee

Difference

Researcher/Canine Handler $184 $244 $60 

Analytical Lab $184 $244 $60 

Maintenance $184 $244 $60 

Detoxification $184 $244 $60 

Maintenance and Detoxification $184 $244 $60 

Compounder/Maintenance $184 $244 $60 

Compounder/Detoxification $184 $244 $60 

Compounder/Maintenance/ Detoxification $184 $244 $60 

Distributor (chemical and controlled substances) $1,147 $1,526 $379 

Reverse distributor $1,147 $1,526 $379 

Importer (chemical and controlled substances) $1,147 $1,526 $379 

Exporter (chemical and controlled substances) $1,147 $1,526 $379 

Manufacturer (chemical and controlled 

substances)

$2,293 $3,052 $759 
Proposed New Registrant Fee Schedule Calculations 2/1/2011

4

The purpose of this document is to allow the reader to understand the various factors that 

contributed to the proposed fee and how these factors were applied in determining the proposed 

fees.

*** DISCLAIMER ***

ALL ASSUMPTIONS, INPUTS, AND CALCULATIONS CONTAINED IN THIS 

DOCUMENT ARE FOR THE PURPOSES OF CALCULATING THE PROPOSED FEE

ONLY. MANY PROCEDURAL, OPERATIONAL, AND ECONOMIC VARIABLES 

CAN CAUSE THE ACTUAL RESULTS TO DIFFER FROM ESTIMATES AND 

PROJECTIONS CONTAINED IN THIS DOCUMENT.
Proposed New Registrant Fee Schedule Calculations 2/1/2011

5

2 Overview of Registrant Fee Calculation Methodology

As the vast majority of registrants are on a three year renewal cycle, the fee calculation is also 

based on a three year analysis, FY 2012-FY 2014. 

The proposed registration fees were calculated through these five major steps:

1. Estimate the required budgets for FY 2012, FY 2013, and FY 2014.

2. Determine the total amount of registration fees that need to be collected over the three year 

period by applying additional factors such as:

a. Payment to Treasury, which increases the amount to be collected from registration fees.

b. Maintaining the Operational Continuity Fund (OCF) balance, which increases the 

amount to be collected from registration fees.

c. Combat Methamphetamine Epidemic Act (CMEA) of 2005 self certification fee 

collections, which decrease the amount that needs to be collected from registration 

fees.

d. Other collections from sale of official government vehicles, which decreases the amount 

to be collected from registration fees.

e. Recoveries from deobligation of prior obligations (see Section 3.2.5 for explanation), 

which decrease the amount that needs to be collected from registration fees.

3. Estimate the total number of registration fee transactions1by business activity, new and 

renewal, over the three year period.

4. Apply the weighted ratio to the total required collections and total number of registrations to 

determine the various fees per each registrant business activity.

5. Finally, apply these fees to the estimated number of registrations by business activity for each of

the three years to determine projected collections per year and estimated OCF balance.

Confirm that the calculated fees allow DEA to recover the full cost of the DCP.

Each of the five steps has multiple sub-steps and components that will be described in Section 3 

of this document. Section 3 details the various components and how these components were 

applied in calculating the proposed fees.

Figure 1: Diagram of Major Components of the Proposed Registration Fee Calculation below 

summarizes the five major steps and key components that were factored into the proposed fee 

calculation.

 

1

“Number of registration fee transactions” is different from the number of registrants. First, fee exempt 

registrations are not included in this number. Second, the registrants on the three year registration cycle will register 

only once in the FY 2012 – FY 2014 period. Since the vast majority of registration (non-fee exempt) fee 

transactions are on the three year registration cycle, the number of registrations per year is roughly one-third the 

number of registrants. In calculating the proposed fee, the “number of registration fee transactions” is a key figure 

discussed in Section 3.3.
Proposed New Registrant Fee Schedule Calculations 2/1/2011

6

Figure 1: Diagram of Major Components of the Proposed Registration Fee Calculation

FY11 Budget

Adjustment for Inflation

FY12 Personnel Cost

FY12 Non-Personnel 

Program Costs

+

+

+

FY12 Budget

FY12 Budget

Adjustment for Inflation

FY13 Staffing Plan

FY13 Non-Personnel 

Program Costs

+

+

+

FY13 Budget

FY13 Budget

Adjustment for Inflation

FY14 Staffing Plan

FY14 Non-Personnel 

Program Costs

+

+

+

FY14 Budget

FY12 Required Registration 

Fee Collections

FY13 Required Registration 

Fee Collections

FY14 Required Registration 

Fee Collections

+ +

Weighted Ratio

Registration Fees by 

Business Activity

FY12 Registrant Population 

by Business Activity

FY13 Registrant Population 

by Business Activity

FY14 Registrant Population 

by Business Activity

+ +

=

=

FY12 Estimated Collection 

and Cash Flow

FY13 Estimated Collection 

and Cash Flow

FY14 Estimated Collection 

and Cash Flow

+ +

FY 2012 FY 2013 FY 2014

FY12-FY14 Required 

Registration Fee Collections

FY12-FY14 Registrant 

Population Projection by 

Business Activity

Step 

1

Step 

2

Step 

3

Step 

4

Color 

Code

Step 

5

Annualization of Prior Year 

Staffing Level Changes

+ /-

Annualization of Prior Year 

Staffing Level Changes

+ /-

Annualization of Prior Year 

Staffing Level Changes

+ /-

FY12 CMEA, Other 

Collections, & Recoveries

-

FY13 CMEA, Other 

Collections, & Recoveries FY12 CMEA Collections - FY13 CMEA Collections - FY14 CMEA Collections

FY12 CMEA, Other 

Collections, & Recoveries

-

FY13 CMEA, Other 

Collections, & Recoveries FY12 Other Collections - FY13 Other Collections - FY14 Other Collections

$15M to Treasury & 

Increase in OCF

+

$15M to Treasury & 

Increase in OCF Increase in OCF Balance + Increase in OCF Balance + Increase in OCF Balance

$15M to Treasury & 

Increase in OCF

+

$15M to Treasury & 

Increase in OCF $15M to Treasury + $15M to Treasury + $15M to Treasury

FY12 CMEA, Other 

Collections, & Recoveries

-

FY13 CMEA, Other 

Collections, & Recoveries FY12 Recoveries - FY13 Recoveries - FY14 Recoveries
Proposed New Registrant Fee Schedule Calculations 2/1/2011

7

3 Proposed Fee Calculation

3.1 Budget: FY 2012-FY 2014

As depicted in Figure 1, the process for formulating the budget for each year is the same. The 

previous year’s budget provides the base level of DCP activities to which various adjustments 

are made to formulate the budget for the given fiscal year.

Cost components and steps taken to formulate the budget for the given fiscal year are:

1. Begin with previous year’s DCFA budget as base level of activities.

2. Make adjustment for cost increases due to inflation.

3. Add Personnel Cost/Staffing Plan: Increase in cost due to addition of personnel.

4. Make adjustment for annualization of prior year staffing level changes: Cost increases or 

decreases due to multi-year effect on cost of adding personnel.

5. Add Non-Personnel Program Costs: Increase in cost due to increase in activities not associated 

with adding personnel or not captured in fully loaded cost of personnel, i.e. rent, outreach 

program, IT system upgrades, etc.

6. Add each adjustment and addition to calculate budget for the given fiscal year.

Section 3.1.1 provides further descriptions of each budget formulation component.

3.1.1 Definition

Prior Year 

Budget

Estimated spending in the year immediately prior to the given fiscal year, the 

year for which budget is being formulated.

Adjustment 

for Inflation

Estimated increase in the cost of prior year’s activities in the new fiscal year 

due to inflation.
Proposed New Registrant Fee Schedule Calculations 2/1/2011

8

Personnel 

Costs

Personnel costs are the costs associated with hiring government personnel. 

These costs include pay, benefits, training, supplies, equipment, and 

operational funding required for a position to perform their job functions. 

DEA’s Office of Resource Management (FR) works with the Department of 

Justice and Office of Management and Budget to develop “Cost Modules” 

for each DEA job category: Special Agent (SA), Diversion Investigator (DI), 

Intel Analyst (IA),2Forensic Chemist (CH), Attorney (AT), Investigative 

Technology Specialist (IT), Professional/Administrative (PA), and 

Technical/Clerical (TC). The fully loaded personnel cost, or modular cost, is 

applied to the planned increase in number of on-board personnel to 

determine the cost of planned staffing increases.

Staffing Plan Staffing Plan is the projected increase in cost due to a planned increase in the 

number of personnel on-board.3 Not all vacant positions were filled in FY 

2011 or FY 2012 due to unbudgeted costs discussed in 3.1.2. In order to fill 

the vacancies in FY 2013 and FY 2014, DCP will need additional resources. 

Annualization 

of Prior Year 

Staffing Level 

Plan

The modular costs used to estimate the cost of staffing level changes includes 

non-recurring costs. Additionally, due to anticipated pay grade increases and 

other job category specific cost changes from 1st to 2nd year and from 2nd to 

the 3rd year, adjustments are made to each of the two following years’ 

budget. This adjustment is called, “Annualization of Prior Year Staffing 

Level Changes.” See Appendix 4 for further explanation and example.

NonPersonnel 

Program 

Costs

Non-Personnel Program Costs are the increases in cost due to new increases 

to DCP activities that are not included in Modular Costs, i.e., rent, outreach 

program,

4

IT system upgrades, or modifications. Non-personnel program 

costs also include the cost of State and Local Task Force Officers (TFOs)5

and Tactical Diversion Squad Contractors (CON) because these are not 

Federal government employees. 

Budget The formulated budget for the given fiscal year.

3.1.2 FY 2012

As described in Section 3.1, the budget formulation for FY 2012 begins with the FY 2011 budget 

as the base year to which adjustments and additions are added for the FY 2012 budget.

 

2

Intel Analysts are sometimes referred to as Intelligence Research Specialists or Intel Specialists (IS).

3

“On-board” refers to personnel occupying a position (not a vacant position). Further explanation is provided in 

Appendix 2.

4

Outreach efforts include DCFA funded personnel educating the public by speaking, presenting, or providing 

assistance regarding DCP activities, e.g. efforts to schedule/control emerging drugs, trends and methods of 

controlled substance diversion, consequences of diversion, and diversion prevention. It also includes liaison efforts 

directly with registrants and indirectly with professional and trade organizations.

5

Task Force Officers (TFO) are also called “State & Local (SL).” The two terms are used interchangeably.
Proposed New Registrant Fee Schedule Calculations 2/1/2011

9

1. FY 2011 DCFA budget is estimated to be $290,304,0006for the level of 

activities described in the “FY 2011 Performance Budget , Drug Enforcement 

Administration, Congressional Budget Submission,” by Department of Justice 

(DOJ). 

$290,304,000

2. The annual adjustment to base to maintain current services is added to the FY

2011 budget. 

$801,000

3. FY 2012 Personnel Costs: DEA plans to increase the number of authorized DCP 

positions by 124. The increase in the number of authorized positions and the 

cost of the increases are indicated below:

$21,492,000

a. Special Agent (SA): 50 $11,782,000

b. Diversion Investigator (DI): 50 $6,844,000

c. Intel Analyst (IA): 9 $1,088,000

d. Forensic Chemist (CH): 3 $742,000

e. Attorney (AT): 1 $121,000

f. Investigative Technology Specialist (IT): 2 $345,000

g. Professional/Administrative (PA): 4 $271,000

h. Technical/Clerical (TC): 5 $298,000

4. FY 2012 Non-Personnel Program Costs: The below costs are increases in nonpersonnel funding for rent, task force officer overtime, and administrative 

support and training for Tactical Diversion Squads (TDSs) task force officers. 

$9,393,000

a. Task Force Officers: $4,288,000

b. Administrative Contractors: $622,000

c. Rent for Task Force Officers: $2,983,000

d. Tactical Diversion Squad Training: $1,500,000

5. The adjustments to the FY 2011 budget and Program Enhancements yield the 

FY 2012 budget of $321,990,000.

$321,990,000

*Numbers are rounded to the thousands to reflect the FY 2012 President’s Budget Submission.

Although authorized positions will be increased for FY 2012, DEA projects that the resources to 

fill all of these positions in FY 2012 will not be available due to the following unbudgeted costs 

to DCP:

Overhead: The DCP’s share of DEA’s overhead costs, such as rent, have been increasing due to 

the increasing proportion of DCP employees to DEA overall. Some of these increases have been 

included as base adjustments or enhancements in prior budget requests and others have been 

funded by realigning program funding. For example, from FY 2007 to FY 2011, DCP rent costs 

 

6

Originally submitted FY 2011 Congressional Budget Submission for DCFA was $291,832,000. Due to a recently 

implemented two year pay freeze, the budget was reduced to $290,304,000.
Proposed New Registrant Fee Schedule Calculations 2/1/2011

10

have increased by $16.4 million, although only $7.9 million have been received as adjustments 

to base or enhancements over the same time period.

The DCP is required to fully fund all diversion activities. Thus, diversion activities that are 

performed by Special Agents and others assigned to non-diversion specific enforcement groups 

or task forces must be funded by the DCP. DEA estimates these costs to be $29,000,000 in FY 

2012. These indirect costs impact the resources available to fill DCP vacancies. We anticipate 

these costs will continue, even when DCP vacancies have been filled. 

Some years Congress has authorized pay raises that exceed the amount estimated in the 

budget. Between FY 2006 and FY 2009, the actual pay raises approved by Congress exceeded 

the budget amount by $2 million. DEA was able to cover the difference for existing positions by 

not filling DCP vacancies. 

DEA projects the following staffing levels by the end of FY 2012:

FY 2012 

Authorized

Positions

FY 2012 

On-board

Estimated 

FY 2012 

Vacancies

Diversion Control Program 1,497 1,195 302

3.1.3 FY 2013 Estimate

Similar to the way in which the FY 2011 budget formed the base level for the FY 2012 budget, 

the FY 2012 budget is the base level to which adjustments and additions are added for the 

estimated FY 2013 budget.

1. FY 2012 DCFA budget is $321,990,000. $321,990,000

2. Annual adjustment for inflation of $7,109,399 (2.2%

7

of $321,990,000) is 

added to the FY 2012 budget. 

$7,109,399

3. FY 2013 Staffing Plan: DEA plans to fill 111 authorized vacant positions

that were unfilled due to unbudgeted costs identified in 3.1.2 above. In 

order to fill the vacancies in FY 2013, DCP will need additional resources. 

The additional resources required are estimated by multiplying the 

number of vacancies to be filled by the modular cost (fully-loaded cost) 

for each job category. The vacancies to be filled and the cost are 

indicated below:

$13,974,434

a. Special Agent (SA): 18 $5,183,132

b. Diversion Investigator (DI): 0 $0

c. Intel Analyst (IA): 26 $3,279,627

d. Forensic Chemist (CH): 4 $998,796

 

7

Annual inflation rate of 2.2% (rounded for display purposes) is used throughout this analysis.
Proposed New Registrant Fee Schedule Calculations 2/1/2011

11

e. Attorney (AT): 3 $371,200

f. Investigative Technology Specialist (IT): 2 $344,328

g. Professional/Administrative (PA): 30 $2,085,431

h. Technical/Clerical (TC): 28 $1,711,920

See Appendix 2: Assumption on Staffing Level for the Purposes of 

Calculating DCP Costs for Registration Fees for a complete list of 

personnel levels from FY 2010 to FY 2014.

See Appendix 3: Modular Costs for each job category.

See Appendix 4: Staffing Plan Costs for explanation of how the Modular 

Costs were applied to calculate staffing plan implementation costs.

4. Annualization of Prior Year Staffing Level Changes: As explained in 

Section 3.1.1, on-board staffing level changes in FY 2011 and FY 2012 

have an impact on the FY 2013 budget.

$4,083,855

a. First year to second year (On-board changes 

from FY 2011 to FY 2012)

$575,000

b. Second year to third year (On-board changes 

from FY 2010 to FY 2011)

$3,508,855

5. Estimated Non Personnel Program Costs. $9,424,634

State & Local/Task Force Officer (SL): $5,420,771

Tactical Diversion Squad Contractors (CON): $776,685

Increased rent and overhead $3,227,178

6. The additions and adjustments to the FY 2012 budget yield the FY 2013 

budget of $356,582,322.

$356,582,322

*Numbers are rounded to the dollar.

DEA plans to fill a total of 141 vacancies in FY 2013, including the 111 vacancies detailed 

above. DEA projects the following staffing levels by the end of FY 2013:

FY 2013

Authorized

Positions

FY 2013

On-board

Estimated 

FY 2013 

Vacancies

Diversion Control Program 1,497 1,336 161
Proposed New Registrant Fee Schedule Calculations 2/1/2011

12

3.1.4 FY 2014 Estimate

Similar to the way in which the FY 2012 budget forms the base level for the FY 2013 budget, the 

FY 2013 is the base level to which adjustments and additions are added for the estimated FY

2014 budget.

1. Estimated FY 2013 DCFA budget is $356,582,322. $356,582,322

2. An annual adjustment for inflation of $7,873,183 (2.2% of $356,582,322) is 

added to the FY 2013 budget. 

$7,873,183 

3. FY 2014 Staffing Plan: DEA plans to continue to fill authorized vacant positions

that were unfilled due to unbudgeted costs identified in 3.1.2 above. DEA plans 

to fill 12 vacancies in FY 2014, which will require additional resources for the 

DCP. The additional resources required are estimated by multiplying the 

number of vacancies to be filled by the modular cost (fully-loaded cost) for each 

job category. The vacancies to be filled and the cost are indicated below:

 $2,622,221

a. Special Agent (SA): 0 $0

b. Diversion Investigator (DI): 0 $0

c. Intel Analyst (IA): 2 $263,240

d. Forensic Chemist (CH): 8 $2,015,578

e. Attorney (AT): 0 $0

f. Investigative Technology Specialist (IT): 2 $343,403

g. Professional/Administrative (PA): 0 $0

h. Technical/Clerical (TC): 0 $0

See Appendix 2: Assumption on Staffing Level for the Purposes of Calculating 

DCP Costs for Registration Fees for a complete list of personnel levels from FY

2010 to FY 2014.

See Appendix 3: Modular Costs for each job category.

See Appendix 4: Staffing Plan Costs for an explanation of how the modular costs 

were applied to calculate the staffing plan implementation costs.

4. Annualization of Prior Year Staffing Level Changes: As explained in Section 

3.1.1, on-board staffing level changes in FY 2012 and FY 2013 have an impact on 

the FY 2014 budget.

$4,753,569 

a. First year to second year (On-board changes 

from FY 2012 to FY 2013)

$2,765,609

b. Second year to Third year (On-board 

changes from FY 2011 to FY 2012)

$1,987,960
Proposed New Registrant Fee Schedule Calculations 2/1/2011

13

5. No increase in Non-Personnel Program Costs. $0

6. The additions and adjustments to the FY 2013 budget yield the FY 2014 budget 

of $371,831,295.

$371,831,295

*Numbers are rounded to the dollar.

DEA projects the following staffing levels by the end of FY 2014:

FY 2014

Authorized

Positions

FY 2014

On-board

Estimated 

FY 2014 

Vacancies

Diversion Control Program 1,497 1,348 149

3.1.5 FY 2012-FY 2014 Summary

Budget Summary FY2012 FY2013 FY2014

Prior Year Obligations 290,304,000 321,990,000 356,582,322 

Annual Adjustment 801,000 

 

7,109,399

 

7,873,183

Personnel Costs 21,492,000

 

13,974,434 2,622,221 

Annualization of Prior Year Staffing Plan**

 

-

 

4,083,855

 

4,753,569

Non-Personnel Program Costs

 

9,393,000 9,424,634 - 

Budget 321,990,000 356,582,322 371,831,295 

*Numbers are rounded.

**See Section 3.1.1 and Appendix 4 for detailed description of “Annualization of Prior Year Staffing Level Changes.”

3.2 Required Collections from Registration Fees

As described in Section 2: Overview of Registrant Fee Calculation Methodology, in order to 

fund the full cost of the DCP, DEA needs to collect enough from registration fees to fund the FY

2012 – FY 2014 budgets and:

1. Make the statutorily required payment to the Treasury, which increases the amount to be 

collected from registration fees.

2. Maintain the targeted Operational Continuity Fund (OCF) balance, which increases the amount 

to be collected from registration fees.

3. Includes estimated Combat Methamphetamine Epidemic Act (CMEA) of 2005 self-certification 

fee collections, which decrease the amount to be collected from registration fees.

4. Adds other collections from the sale of personal property and official government vehicles, 

which decreases the amount that needs to be collected from registration fees.

5. Estimates recoveries from money not spent as planned (deobligation of prior obligations) (see 

Section 3.2.5 for an explanation), which decreases the amount that needs to be collected from 

registration fees.
Proposed New Registrant Fee Schedule Calculations 2/1/2011

14

3.2.1 Payment to Treasury

In the 1993 appropriations for DEA, Congress determined that the DCP would be fully funded 

by registration fees and no longer by appropriations.8 Congress established the DCFA as a 

separate account of the Treasury to “ensure the recovery of the full costs of operating the various 

aspects of [the Diversion Control Program]” by those participating in the closed system 

established by the CSA. 21 U.S.C. 886a(1)(C). Fees collected are deposited into a separate 

Treasury account. Each fiscal year, the first $15 million is transferred to the Treasury and is not 

available for use by the DCP. Therefore, DEA needs to collect an additional $15 million per 

year for payment to Treasury. 

3.2.2 Operational Continuity Fund (OCF) 

DEA maintains an operational continuity fund (OCF) to maintain DCP operations during 

historically low (or negative) collection periods (e.g., the first quarter of a new fiscal year when 

the first $15 million collected is transferred to Treasury). Monthly collections and obligations 

fluctuate throughout the year. There are times when obligations (spending) exceed collections. 

This can happen consecutively for several months. Therefore, an operational continuity fund is 

maintained to avoid operational disruptions due to these fluctuations and monthly differences in 

collections and obligations (spending). Using statistical analysis of the historical fluctuations 

between amounts collected and amounts obligated, DEA has determined that a reserve fund of 

$15 million plus seven percent of the projected obligations is adequate. See Appendix 5: Target 

Operational Continuity Fund for an explanation of how this level was determined. The amount 

required to bring the operational continuity fund balance to the $15 million plus a seven percent 

level is added to projected costs.

The table below summarizes the targeted OCF balances and amounts needed to raise the OCF 

balance to the targeted balance:

FY2012 FY2013 FY2014

Budget 321,990,000 356,582,322 371,831,295 

Target OCF ($15M + 7%) 39,960,763 41,028,191 41,828,482 

Beginning OCF balance 33,508,367 

Needed Increase to 

Achieve Target OCF 6,452,395 1,067,428 800,291 

3.2.3 Combat Methamphetamine Epidemic Act of 2005 (CMEA) Collections

Under CMEA, DEA collects a self-certification fee for regulated sellers of scheduled listed 

chemical products that are included as part of the total collections. The fee is waived for any 

person holding a current DEA registration in good standing, such as a pharmacy, authorized to 

dispense controlled substances. DEA has observed an approximately 15 percent decline in selfcertifications from FY 2008 to FY 2010 and anticipates that the decline will continue through FY

2014. The self-certification fee is $21 and is paid on an annual basis. The CMEA selfcertification fee collection estimates for FY 2012 – FY 2014 are below:

 

8

Departments of Commerce, Justice, and State, the Judiciary and Related Agencies Appropriations Act of 1993, 

Public Law 102-395, codified in relevant part at 21 U.S.C. 886a.
Proposed New Registrant Fee Schedule Calculations 2/1/2011

15

FY12 FY13 FY14

Number of paying self-certifications 8,240 6,993 5,935

Fee $21 $21 $21 

CMEA collection estimate $173,040 $146,853 $124,635 

3.2.4 Other Collections

DEA also derives revenue from the sale/salvage of official government vehicles dedicated for 

use within the DCP. DEA’s estimate for other collections is $307,153 per year. This is the 

actual amount for FY 2010.

3.2.5 Recoveries from Money Not Spent as Planned (Deobligation of Prior 

Year Obligations)

At times, DEA enters into an obligation to make a purchase of a product or service that is not 

delivered immediately, such as in a multi-year contract. Changes in obligations can occur for a 

variety of reasons, i.e., changes in planned operations, delays in staffing, implementation of cost 

savings, changes in vendor capabilities, etc. When DEA does not spend money planned to be 

spent, that obligation is “deobligated.” The “deobligated” funds are “recovered” and the funds

become available for DCP use. Based on historical trends, the recovery from money not spent as 

planned (deobligation of prior year obligations) is estimated at $10 million per year.

3.2.6 Summary

The required registration fee collections for FY 2012 – FY 2014 are summarized below:

FY2012 FY2013 FY2014 3-yr Total

Budget 321,990,000 356,582,322 371,831,295 1,050,403,617 

Recoveries

 

(10,000,000)

 

(10,000,000)

 

(10,000,000)

 

(30,000,000)

Net Budget 311,990,000 346,582,322 361,831,295 1,020,403,617 

Payment to Treasury

 

15,000,000 

 

15,000,000 

 

15,000,000 

 

45,000,000 

Needed Increase to Achieve Target OCF

 

6,452,395 

 

1,067,428 800,291 

 

8,320,115 

CMEA Self-cert collections

 

(173,040)

 

(146,853)

 

(124,635)

 

(444,528)

Other collections

 

(307,153)

 

(307,153)

 

(307,153)

 

(921,458)

Required collections from Registration 

Fees 332,962,203 362,195,745 377,199,798 1,072,357,746 

*Numbers are rounded.

DEA needs to collect $1,072,357,746 in registration fees over the three year period, FY 2012 –

FY 2014 to fully fund the DCP.
Proposed New Registrant Fee Schedule Calculations 2/1/2011

16

3.3 Estimated Number of Registration Fee Transactions: FY 2012 – F 2014

In Section 3.2, DEA determined that the required collection over the three year FY 2012 – FY

2014 period must be $1,072,357,746. To determine the registration fees, the number of 

registration fee transactions by business activity was estimated. Although related, the number of 

registration fee transactions is different from the registrant population for three primary reasons. 

One, registrants on a three year registration cycle have only one registration fee transaction every 

three years. Registration renewal dates are staggered across a three year period to generate 

registration fee transactions from roughly one-third of these registrants each year. Two, a

registrant may have multiple registrations, paying multiple fees. Three, approximately seven

percent of the registrant population is exempt from paying registration fees. 

Based on historical data, the table below summarizes the estimated number of registration fee 

transactions for FY 2012 – FY 2014. See Appendix 6: Estimated Number of Registration Fee 

Transactions for details on how the estimate was derived.

Group Business Activity 2012 2013 2014 Total

3 year 

registration

A Pharmacy 25,462 23,050 25,901 74,413 

B Hospital/Clinic 4,456 4,553 4,647 13,656 

C Practitioner 376,425 366,802 382,390 1,125,617 

D Teaching Institution 81 68 73 222 

M Mid-level Practitioner (MLP) 70,821 72,309 79,037 222,167 

1 year registration

E Manufacturer 534 536 536 1,606 

F Distributor 713 718 722 2,153 

G Researcher/Canine Handler 4,181 4,308 4,440 12,929 

H Analytical Lab 902 898 895 2,695 

J Importer 212 214 216 642 

K Exporter 245 246 247 738 

L Reverse Distributor 65 66 67 198 

N Maintenance 178 180 181 539 

P Detoxification 78 78 78 234 

R Maintenance & Detox 875 888 900 2,663 

S Compounder/Maintenance 5 5 5 15 

T Compounder/Detoxification 1 1 1 3 

U Compounder/Maintenance/Detox 52 52 52 156 

W Chemical Manufacturer 228 232 235 695 

X Chemical Importer 185 186 187 558 

Y Chemical Distributor 387 290 217 894 

Z Chemical Exporter 177 180 183 540 

Total 486,263 475,860 501,210 1,463,333 

Groups A, B, C, D, and M renew their registration every three years. The remaining groups 

renew annually. The 1,463,333 registrations over the three year period will need to result in 

collections of $1,072,357,746.
Proposed New Registrant Fee Schedule Calculations 2/1/2011

17

3.4 Proposed Registration Fees by Business Activity

The proposed registration fees are based on:

1. The amount that needs to be collected (determined in Section 3.2).

2. The number of transactions/registration fee transactions (determined in Section 3.3).

3. The share of cost burden (relative fees) across various registrant groups

DEA examined four options and decided to use the “weighted-ratio” approach to set varying fees 

across registrant groups. A discussion of the other options considered is beyond the scope of this 

document.

As in previous fee schedules, the fees for distributors, importers, and exporters are 6.25 times the 

fees for retail level registrants and manufacturer fees are two times the fees for distributors. The 

table below describes the relative difference among the groups: 

Group Business Activity Ratio

A Pharmacy 3.00 

B Hospital/Clinic 3.00 

C Practitioner 3.00 

D Teaching Institution 3.00 

M Mid-level Practitioner (MLP) 3.00 

E Manufacturer 12.50 

F Distributor 6.25 

G Researcher/Canine Handler 1.00 

H Analytical Lab 1.00 

J Importer 6.25 

K Exporter 6.25 

L Reverse Distributor 6.25 

N Maintenance 12.50 

P Detoxification 1.00 

R Maintenance & Detox 1.00 

S Compounder/Maintenance 1.00 

T Compounder/Detoxification 1.00 

U Compounder/Maintenance/Detox 1.00 

W Chemical Manufacturer 12.50 

X Chemical Importer 6.25 

Y Chemical Distributor 6.25 

Z Chemical Exporter 6.25 

Fees for groups A, B, C, D, and M are three times the other retail level registrants: G, H, P, R, S, 

T, and U. Since these groups are on a three year renewal cycle, the annualized fee remains the 

same as for other retail level registrants.
Proposed New Registrant Fee Schedule Calculations 2/1/2011

18

The number of registration fee transactions in Section 3.3 can be simplified as below:

Groups Ratio

Registration 

Fee 

Transactions: 

FY12-FY14

Distributor F,L,Y 6.25 3,245 

Importer/Exporter J,K,X,Z 6.25 2,478 

Manufacturer E,W 12.50 2,301 

Retail, 1-yr G,H,N,P,R,S,T,U 1.00 19,234 

Retail, 3-yr A,B,C,D,M 3.00 1,436,075 

Total 1,463,333 

After assigning the ratio as weights, a simple algebraic expression is used to calculate the fees:

(6.25x * 3,245) + (6.25x * 2,478) + (12.50x * 2,301) + (1.00x * 19,234) + (3.00x * 1,436,075) = 

$1,072,357,746

Solving for x, x = $244.16 (Retail, 1-yr)

By applying the weights/ratio, the calculated fees are shown in the table below, rounded to the 

whole dollar. 

Groups Ratio

Registration 

Fee 

Transactions: 

FY12-FY14

Calculated 

Fee

Rounded 

Fee

Distributor F,L,Y 6.25 3,245 1,526.01 1,526 

Importer/Exporter J,K,X,Z 6.25 2,478 1,526.01 1,526 

Manufacturer E,W 12.50 2,301 3,052.03 3,052 

Retail, 1-yr G,H,N,P,R,S,T,U 1.00 19,234 244.16 244 

Retail, 3-yr A,B,C,D,M 3.00 1,436,075 732.49 732 

3.5 Estimated Collections from Registration Fees

Due to rounding, the registration fees will not generate exactly $1,072,357,746. Therefore, the 

number of registrations for each group is multiplied by the fee for each group and summed to 

calculate the estimated collections based on proposed fees, $1,071,655,946. The table below 

summarizes the estimated collections from registration fees for the three years, FY 2012 – FY

2014.

FY2012 FY2013 FY2014 Total (3-yr)

Collections from Registration 

Fees

 

356,226,916 

 

348,491,800 

 

366,937,230 

 

1,071,655,946 

See Appendix 7: Collections Estimates Based on Proposed Fee for a detailed calculation.
Proposed New Registrant Fee Schedule Calculations 2/1/2011

19

4 Summary of Results

The table below summarizes the proposed fee and resulting cash flow:

Fees

Group Business Current Fee Ratio Proposed Fee

A Pharmacy 551 3 732

B Hospital/Clinic 551 3 732

C Practitioner 551 3 732

D Teaching Institution 551 3 732

M Mid-level Practitioner (MLP) 551 3 732

E Manufacturer 2,293 12.5 3,052

F Distributor 1,147 6.25 1,526

G Researcher/Canine Handler 184 1 244

H Analytical Lab 184 1 244

J Importer 1,147 6.25 1,526

K Exporter 1,147 6.25 1,526

L Reverse Distributor 1,147 6.25 1,526

N Maintenance 184 1 244

P Detoxification 184 1 244

R Maintenance & Detox 184 1 244

S Compounder/Maintenance 184 1 244

T Compounder/Detoxification 184 1 244

U Compounder/Maintenance/Detox 184 1 244

W Chemical Manufacturer 2,293 12.5 3,052

X Chemical Importer 1,147 6.25 1,526

Y Chemical Distributor 1,147 6.25 1,526

Z Chemical Exporter 1,147 6.25 1,526
Proposed New Registrant Fee Schedule Calculations 2/1/2011

20

FY2011 FY2012 FY2013 FY2014

Congressional Budget

 

290,304,000 

 

321,990,000 

 

356,582,322 

 

371,831,295 

Operational Continuity Fund (OCF) 

Brought Forward From Prior Year

 

68,089,927 

 

33,508,367 

 

63,225,476 

 

50,588,959 

Collections: Registration Fees

 

257,254,274 

 

356,226,916 

 

348,491,800 

 

366,937,230 

Collections: CMEA

 

203,889 

 

173,040 

 

146,853 

 

124,635 

Treasury

 

(15,000,000)

 

(15,000,000)

 

(15,000,000)

 

(15,000,000)

Net Collections

 

242,458,163 

 

341,399,956 

 

333,638,653 

 

352,061,865 

Recoveries from Deobligations

 

12,957,124 

 

10,000,000 

 

10,000,000 

 

10,000,000 

Other Collections

 

307,153 

 

307,153 

 

307,153 

 

307,153 

Subtotal Availability

 

323,812,367 

 

385,215,476 

 

407,171,281 

 

412,957,977 

Obligations*

 

290,304,000 

 

321,990,000 

 

356,582,322 

 

371,831,295 

End of Year OCF Balance

 

33,508,367 

 

63,225,476 

 

50,588,959 

 

41,126,682 

Target OCF ($15M+7% of Budget)

 

37,539,300 

 

39,960,763 

 

41,028,191 

 

41,828,482 

 Numbers are rounded.

 *For purposes of the proposed fee calculation, the Congressional Budget and Obligations are treated as the same.
Proposed New Registrant Fee Schedule Calculations 2/1/2011

21

5 Factors that Can Influence Actual Results

All assumptions, inputs, and calculations contained in this document are for the purposes of 

calculating the proposed fee only. Many procedural, operational, and economic variables can 

cause the actual results to differ from estimates and projections contained in this document. 

Factors include (but are not limited to):

Delay in New Fee 

Effective Date

Collections and budget estimates are based on proposed fees being 

effective beginning October 1, 2011. Any delay will have a large 

impact on the registration fees collected. Additionally, projected 

spending will also be impacted as operations are adjusted to meet 

financial constraints.

Change in Proposed 

Fee

Collections and budget estimates are based on the calculated 

proposed fees. Any change in the amount will have a large impact 

on the registration fees collected. Additionally, projected spending 

will also be impacted as operations are adjusted to meet financial 

constraints.

New 

Legislative/Regulatory 

Mandate

A new legislative/regulatory mandate can require more spending 

and greatly impact cash flow.

Changes in 

Technology

New technology can be leveraged to improve efficiency and 

effectiveness within the Diversion Control Program. Technology can 

also be exploited by criminal groups to illegally divert controlled 

substances or listed chemicals.

Change in Staffing 

Level or Mix

Staffing increases account for the majority of budget increases. 

Changes in diversion trends may require DEA to change the level or 

mix (mix of job categories) in staffing, which would impact spending.

Change in Registrant 

Population

The registration fee collection projection assumes a certain level of 

new registrants and renewals. The actual number of registrations 

will impact collections from registrant fees and cash flow.

Change in Annual 

Inflation of DEA Costs

2.2 percent is assumed for an annual inflation increase in DEA costs

(except for cost increases in modular costs, where historical cost 

increases for each job category and lapse 50 percent, second year, 

and third year). Actual inflation increases different from this 

assumed value can impact obligations/expenditures. Depending on 

the severity, operational adjustments may be required. 
Proposed New Registrant Fee Schedule Calculations 2/1/2011

22

Appendix 1: List of Acronyms

Acronym Definition

AT Attorney

CAGR Compound Annual Growth Rate

CH Forensic Chemist

CMEA Combat Methamphetamine Epidemic Act of 2005

CON Tactical Diversion Squad Contractor

CSA Controlled Substances Act

DCFA Diversion Control Fee Account

DCP Diversion Control Program

DEA Drug Enforcement Administration

DI Diversion Investigator

DOJ Department of Justice

EOY End of Year

FR DEA Office of Resource Management

FY Fiscal Year

GS General Schedule

IA Intel Analyst

IT Investigative Technology Specialist

LEAP Law Enforcement Availability Pay

MET Mobile Enforcement Team

MLP Mid-level Practitioner

OCF Operational Continuity Fund

OF Other Federal

OT Overtime

PA Professional/Administrative

PE/PI Purchase of Evidence/Purchase of Information

SA Special Agent

PCS Permanent Change of Station

SL State & Local

TC Technical/Clerical

TDS Tactical Diversion Squad

TFO Task Force Officer
Proposed New Registrant Fee Schedule Calculations 2/1/2011

23

Appendix 2: Assumptions on Staffing Levels for the Purposes of 

Calculating DCP Cost for Registration Fees

Actual Estimate

FY2010 FY2011 FY2012 FY2013 FY2014

Special Agent Enhancements - 62 50 - -

(SA) Authorized 179 241 291 291 291

Allocated 179 179 239 291 291

On Board 144 154 214 262 262

Diversion Investigator Enhancements - 60 50 - -

(DI) Authorized 516 576 626 626 626

Allocated 516 549 565 626 626

On Board 461 525 565 565 565

Intel Analyst Enhancements - 14 9 - -

(IA) Authorized 73 87 96 96 96

Allocated 73 73 73 96 96

On Board 57 58 58 84 86

Forensic Chemist Enhancements 11 4 3 - -

(CH) Authorized 19 23 26 26 26

Allocated 19 19 19 26 26

On Board 8 11 11 15 23

Attorney Enhancements - 5 1 - -

(AT) Authorized 18 23 24 24 24

Allocated 18 18 19 24 24

On Board 21 19 19 22 22

Investigative Technolgy Enhancements - 3 2 - -

Specialist Authorized 2 5 7 7 7

(IT) Allocated 2 2 2 7 7

On Board 2 2 2 4 6

Professional/ Enhancements 1 11 4 -

Administrative Authorized 244 255 259 259 259

(PA) Allocated 244 244 244 259 259

On Board 204 203 203 233 233

Technical/Clerical Enhancements (1) 15 5 - -

(TC) Authorized 148 163 168 168 168

Allocated 148 148 148 168 168

On Board 125 123 123 151 151

Total Government Enhancements 11 174 124 - -

Authorized 1,199 1,373 1,497 1,497 1,497

Allocated 1,199 1,232 1,309 1,497 1,497

On Board 1,022 1,095 1,195 1,336 1,348

State & Local Enhancements (2) 64 64 - -

(SL) Authorized 294 358 422 422 422

Allocated 294 294 294 294 294

On Board 118 118 118 180 180

Other Federal Enhancements 1 - - - -

Authorized 7 7 7 7 7

Allocated 7 7 7 7 7

On Board 4 4 6 6 6

TDS Contractors Enhancements - 8 8 - -

Authorized 37 45 53 53 53

Allocated 37 37 53 53 53

On Board 35 37 37 53 53

Total Government, Enhancements 10 246 196 - -

State & Local, Authorized 1,537 1,783 1,979 1,979 1,979

Other Federal, and Allocated 1,537 1,570 1,663 1,851 1,851

Contractor On Board 1,179 1,254 1,356 1,575 1,587

Estimate Enhancements:

Authorized Positions:

Allocated Positions:

On-board Positions

Increase in Authorized Positions in the 

budget year.

Number of positions authorized by the 

Congressional Budget

Number of positions allocated in DEA's 

Table of Organization. DCP portion of 

rent for shared, DCP and Non-DCP, space 

is calculated using the number of 

allocated positions. A position can 

remain unallocated for a variety of 

reasons, and are held as reserve until 

allocated.

Number of allocated positions filled. 

Personnel enhancement cost is driven 

by changes in On-board Positions.
Proposed New Registrant Fee Schedule Calculations 2/1/2011

24

Appendix 3: Modular Costs

Modular Costs (also called “Cost Module”) are developed by DEA Office of Resource 

Management (FR) and represent the fully loaded cost of an employee, with the exception of rent 

and new initiatives. A separate cost module is developed for each job category: Special Agent 

(SA), Diversion Investigator (DI), Intel Analyst (IA), Forensic Chemist (CH), Attorney (AT), 

Investigative Technology Specialist (IT), Professional/Administrative (PA), and 

Technical/Clerical (TC). Additionally, the SA cost module is modified to develop the Task 

Force Officer9cost module. The cost module for Tactical Diversion Squad (TDS) contractor 

was developed by the Office of Diversion Control, Diversion Planning and Resources Section 

(ODA).

FY 2012 Modular Costs were used to estimate the cost of personnel increases from FY 2012 and 

beyond. FY 2011 Modular Costs were used to estimate the annualization of prior year staffing 

level changes. The first year cost of new employee is assumed to be for six months. Cost 

module assumes that some employees may come on-board early in the year, some late in the 

year, therefore, average of “50% lapse” into the fiscal year. Payroll and most of the operational 

costs are lapsed 50 percent, while non-recurring equipment and infrastructure costs are at full 

cost. 

FY 2012 Domestic Cost Module Estimates

Position: Special Agent

Object Class 2012 Cost 2013 Cost 2014 Cost

Pay and Benefits 47,339 112,361 180,571

Travel and Transportation of Things 78 3,478 3,478

Facility Overhead 2,673 5,407 5,407

Services 19,200 1,989 1,989

Investigative and Administrative Supplies 6,507 5,621 5,621

Office Equipment and Technology 21,570 4,098 4,098

Investigative Equipment 85,416 22,522 22,522

Training 30,556 4,585 4,585

Operational Expenses 0 24,283 24,283

PCS 22,302 36,507 36,507

Total 235,641 220,851 289,061

 

9

TFO’s and SA’s are functionally similar, while the TFO cost module is considerably lower than the SA cost 

module. Inclusion of TFOs in the DCP aids in reducing the cost of the DCP.
Proposed New Registrant Fee Schedule Calculations 2/1/2011

25

Position: Diversion Investigator

Object Class 2012 Cost 2013 Cost 2014 Cost

Pay and Benefits 33,538 82,227 131,926

Travel and Transportation of Things 78 3,478 3,478

Facility Overhead 2,616 5,291 5,291

Services 12,836 1,465 1,465

Investigative and Administrative Supplies 1,265 2,253 2,253

Office Equipment and Technology 20,816 3,910 3,910

Investigative Equipment 52,561 15,041 15,041

Training 13,174 3,076 3,076

PCS 0 17,679 17,679

Total 136,884 134,420 184,119

Position: Intelligence Analyst

Object Class 2012 Cost 2013 Cost 2014 Cost

Pay and Benefits 33,538 82,227 131,926

Travel and Transportation of Things 78 3,478 3,478

Facility Overhead 2,323 4,701 4,701

Services 9,333 1,285 1,285

Investigative and Administrative Supplies 924 1,337 1,337

Office Equipment and Technology 52,126 19,390 19,390

Investigative Equipment 2,877 1,046 1,046

Training 19,688 3,400 3,400

PCS 0 25,268 25,268

Total 120,887 142,132 191,831

Position: Chemist

Object Class 2012 Cost 2013 Cost 2014 Cost

Pay and Benefits 33,538 82,227 131,926

Travel and Transportation of Things 78 4,850 4,850

Facility Overhead 5,699 11,595 11,595

Services 8,867 1,803 1,803

Investigative and Administrative Supplies 9,550 9,417 9,417

Office Equipment and Technology 20,816 3,910 3,910

Investigative Equipment 152,235 30,447 30,447

Training 7,909 4,967 4,967

PCS 8,779 24,255 24,255

Total 247,471 173,471 223,170
Proposed New Registrant Fee Schedule Calculations 2/1/2011

26

Position: Attorney

Object Class 2012 Cost 2013 Cost 2014 Cost

Pay and Benefits 77,247 182,812 182,812

Travel and Transportation of Things 1,720 3,478 3,478

Facility Overhead 2,387 4,828 4,828

Services 15,520 17,438 17,438

Administrative Supplies 653 1,113 1,113

Office Equipment and Technology 21,570 4,098 4,098

Training 1,409 3,249 3,249

Total 120,506 217,016 217,016

Position: Investigative Technology Specialist

Object Class 2012 Cost 2013 Cost 2014 Cost

Pay and Benefits 39,833 97,527 156,835

Travel and Transportation of Things 78 3,478 3,478

Facility Overhead 2,673 5,407 5,407

Services 8,368 1,523 1,523

Administrative Supplies 2,069 4,185 4,185

Office Equipment and Technology 20,816 3,910 3,910

Investigative Equipment 78,311 21,227 21,227

Training 20,479 3,914 3,914

Total 172,627 141,171 200,479

Position: Professional Administrative

Object Class 2012 Cost 2013 Cost 2014 Cost

Pay and Benefits 33,538 82,227 131,926

Travel and Transportation of Things 1,720 3,478 3,478

Facility Overhead 2,054 4,163 4,163

Services 7,802 1,821 1,821

Administrative Supplies 447 904 904

Office Equipment and Technology 20,816 3,910 3,910

Training 1,494 3,347 3,347

Total 67,871 99,850 149,549

Position: Technical Clerical

Object Class 2012 Cost 2013 Cost 2014 Cost

Pay and Benefits 27,713 69,955 69,955

Travel and Transportation of Things 78 3,478 3,478

Facility Overhead 2,017 4,089 4,089

Services 7,802 1,821 1,821

Administrative Supplies 447 904 904

Office Equipment and Technology 20,816 3,910 3,910

Training 765 1,860 1,860

Total 59,638 86,017 86,017
Proposed New Registrant Fee Schedule Calculations 2/1/2011

27

Position: State & Local (Task Force Officer)

Object Class 2012 Cost 2013 Cost 2014 Cost

Travel and Transportation of Things 77 3,478 3,478

Facility Overhead 2,672 5,406 5,406

Services 9,579 17,734 17,734

Investigative and Administrative Supplies 5,938 5,431 5,431

Office Equipment and Technology 21,570 4,098 4,098

Investigative Equipment 44,524 14,391 14,391

Training 0 3,039 3,039

Operational Expenses 0 24,283 24,283

Total 84,360 77,860 77,860

Modular Cost: Tactical Diversion Squad Contractor (CON)

(Based on contract)

FY2011 FY2012 FY2013 FY2014

Cost per Data Analyst 90,779.69 93,871.85 97,085.64 100,414.16 

Lapse 50% 45,389.84 46,935.93 48,542.82 50,207.08 

FY 2011 Domestic Cost Module Estimates

Position: Special Agent

Object Class 2011 Cost 2012 Cost 2013 Cost

Pay and Benefits 47,025 111,482 178,936

Travel and Transportation of Things 79 3,459 3,459

Facility Overhead 2,698 5,500 5,500

Services 21,779 3,830 3,830

Investigative and Administrative Supplies 7,283 7,218 7,218

Office Equipment and Technology 23,303 4,450 4,450

Investigative Equipment 87,971 22,777 22,777

Training 25,060 4,382 4,382

Operational Expenses 0 23,854 23,854

PCS 19,642 35,912 35,912

Total 234,840 222,864 290,318
Proposed New Registrant Fee Schedule Calculations 2/1/2011

28

Position: Diversion Investigator

Object Class 2011 Cost 2012 Cost 2013 Cost

Pay and Benefits 35,346 86,890 139,261

Travel and Transportation of Things 79 3,459 3,459

Facility Overhead 2,645 5,393 5,393

Services 18,240 3,261 3,261

Investigative and Administrative Supplies 1,569 2,860 2,860

Office Equipment and Technology 22,467 4,241 4,241

Investigative Equipment 52,466 14,762 14,762

Training 13,233 3,095 3,095

PCS 0 17,695 17,695

Total 146,045 141,656 194,027

Position: Intelligence Analyst

Object Class 2011 Cost 2012 Cost 2013 Cost

Pay and Benefits 35,329 86,855 139,226

Travel and Transportation of Things 79 3,459 3,459

Facility Overhead 2,118 4,318 4,318

Services 9,755 3,017 3,017

Investigative and Administrative Supplies 941 1,516 1,516

Office Equipment and Technology 50,366 16,567 16,567

Investigative Equipment 2,841 1,038 1,038

Training 21,423 3,468 3,468

PCS 0 26,391 26,391

Total 122,852 146,629 199,000

Position: Chemist

Object Class 2011 Cost 2012 Cost 2013 Cost

Pay and Benefits 35,329 86,855 139,226

Travel and Transportation of Things 79 3,805 3,805

Facility Overhead 5,724 11,675 11,675

Services 9,795 3,567 3,567

Investigative and Administrative Supplies 9,154 9,577 9,577

Office Equipment and Technology 22,467 4,241 4,241

Investigative Equipment 155,011 31,622 31,622

Training 6,934 4,971 4,971

PCS 6,672 18,503 18,503

Total 251,165 174,816 227,187
Proposed New Registrant Fee Schedule Calculations 2/1/2011

29

Position: Attorney

Object Class 2011 Cost 2012 Cost 2013 Cost

Pay and Benefits 81,404 192,882 192,882

Travel and Transportation of Things 1,696 3,459 3,459

Facility Overhead 2,294 4,676 4,676

Services 13,575 13,516 13,516

Administrative Supplies 691 1,181 1,181

Office Equipment and Technology 23,303 4,450 4,450

Training 1,446 3,320 3,320

Total 124,409 223,484 223,484

Position: Investigative Technology Specialist

Object Class 2011 Cost 2012 Cost 2013 Cost

Pay and Benefits 43,967 107,821 173,284

Travel and Transportation of Things 79 3,459 3,459

Facility Overhead 2,631 5,364 5,364

Services 9,221 3,249 3,249

Administrative Supplies 2,834 5,781 5,781

Office Equipment and Technology 22,467 4,241 4,241

Investigative Equipment 94,148 24,181 24,181

Training 6,845 3,368 3,368

Total 182,192 157,464 222,927

Position: Professional Administrative

Object Class 2011 Cost 2012 Cost 2013 Cost

Pay and Benefits 35,346 86,890 139,261

Travel and Transportation of Things 1,696 3,459 3,459

Facility Overhead 2,144 4,373 4,373

Services 8,715 3,602 3,602

Administrative Supplies 467 953 953

Office Equipment and Technology 22,467 4,241 4,241

Training 1,494 3,391 3,391

Total 72,329 106,909 159,280

Position: Technical Clerical

Object Class 2011 Cost 2012 Cost 2013 Cost

Pay and Benefits 29,147 73,958 73,959

Travel and Transportation of Things 79 3,459 3,459

Facility Overhead 2,091 4,264 4,264

Services 8,715 3,602 3,602

Administrative Supplies 467 953 953

Office Equipment and Technology 22,467 4,241 4,241

Training 1,511 1,892 1,892

Total 64,477 92,369 92,370
Proposed New Registrant Fee Schedule Calculations 2/1/2011

30

Position: State & Local (Task Force Officer)

Object Class 2011 Cost 2012 Cost 2013 Cost

Travel and Transportation of Things 79 3,459 3,459

Facility Overhead 2,698 5,500 5,500

Services 9,538 17,721 17,721

Investigative and Administrative Supplies 6,700 7,022 7,022

Office Equipment and Technology 23,303 4,450 4,450

Investigative Equipment 44,165 13,984 13,984

Training 0 3,104 3,104

Operational Expenses 0 23,854 23,854

Total 86,483 79,094 79,094
31

Appendix 4: Staffing Plan Implementation Cost

The cost modules in Appendix 3 are summarized into tables below, with the exception of the SA 

cost module which has been modified (see explanation on the side).

FY2011 FY2012 FY2013 FY2014

SA

50% Lapse 276,358 277,835 287,952 298,437

2nd Yr 290,318 289,061 298,082 307,386

3rd Yr 290,318 289,061 298,082 307,386

Annualization 50% Lapse to 2nd Yr 13,961 11,226 10,131 8,949

Annualization 2nd Yr to 3rd Yr - - - -

DI

50% Lapse 146,045 136,884 137,918 138,959

2nd Yr 141,656 134,420 136,588 138,791

3rd Yr 194,027 184,119 187,479 190,901

Annualization 50% Lapse to 2nd Yr (4,389) (2,464) (1,330) (168)

Annualization 2nd Yr to 3rd Yr 52,371 49,699 50,891 52,110

IA

50% Lapse 122,852 120,887 126,139 131,620

2nd Yr 146,629 142,132 147,514 153,099

3rd Yr 199,000 191,831 198,394 205,181

Annualization 50% Lapse to 2nd Yr 23,777 21,245 21,374 21,479

Annualization 2nd Yr to 3rd Yr 52,371 49,699 50,880 52,081

CH

50% Lapse 251,165 247,471 249,699 251,947

2nd Yr 174,816 173,471 177,744 182,123

3rd Yr 227,187 223,170 228,641 234,246

Annualization 50% Lapse to 2nd Yr (76,349) (74,000) (71,955) (69,824)

Annualization 2nd Yr to 3rd Yr 52,371 49,699 50,897 52,123

AT

50% Lapse 124,409 120,506 123,733 127,047

2nd Yr 223,484 217,016 222,936 229,017

3rd Yr 223,484 217,016 222,936 229,017

Annualization 50% Lapse to 2nd Yr 99,075 96,510 99,202 101,970

Annualization 2nd Yr to 3rd Yr - - - -

IT

50% Lapse 182,192 172,627 172,164 171,702

2nd Yr 157,464 141,171 145,738 150,453

3rd Yr 222,927 200,479 207,974 215,748

Annualization 50% Lapse to 2nd Yr (24,728) (31,456) (26,426) (21,249)

Annualization 2nd Yr to 3rd Yr 65,463 59,308 62,235 65,295

PA

50% Lapse 72,329 67,871 69,514 71,198

2nd Yr 106,909 99,850 101,886 103,963

3rd Yr 159,280 149,549 152,781 156,084

Annualization 50% Lapse to 2nd Yr 34,580 31,979 32,371 32,765

Annualization 2nd Yr to 3rd Yr 52,371 49,699 50,896 52,121

TC

50% Lapse 64,477 59,638 61,140 62,680

2nd Yr 92,369 86,017 88,006 90,041

3rd Yr 92,370 86,017 88,006 90,041

Annualization 50% Lapse to 2nd Yr 27,892 26,379 26,866 27,361

Annualization 2nd Yr to 3rd Yr 1 - - -

SL (1 car for 1 persons)

50% Lapse 86,483 84,360 87,432 90,615

2nd Yr 79,094 77,860 80,505 83,240

3rd Yr 79,094 77,860 80,289 82,795

Annualization 50% Lapse to 2nd Yr (7,389) (6,501) (6,927) (7,376)

Annualization 2nd Yr to 3rd Yr - - (215) (444)

Contractor

50% Lapse 45,390 46,936 48,543 50,207

2nd Yr 90,780 93,872 97,086 100,414

3rd Yr 90,780 93,872 97,086 100,414

Annualization 1st Yr to 2nd Yr 45,390 46,936 48,543 50,207

Annualization 2nd Yr to 3rd Yr - - - -

Except SA 50% lapse, non-shaded numbers 

are directly copied from the cost modules 

while shaded numbers are calculated values.

SAs in DCP usually enter DCP as grade GS-13. 

Therefore, 50% lapse of $276,358 and 

$277,835 are determined by combining the 

third year payroll cost with the first year 

operational and equipment costs. Second 

year and third year costs are both based on 

the third year costs.

FY 2013 and FY 2014 costs are estimated 

using historical changes in these costs. (See 

the table on the next page.)

“Annualization 50% Lapse to 2nd Yr” is the cost 

difference between the base budget from the 

50% Lapse and the second year. For example, 

a new DI in FY 2011 costs $146,045 and the 

budget for FY 2011 will increase by this 

amount. In FY 2012 (2nd Year), the same DI 

would cost $141,656 so there is an 

annualization decrease of $4,389 for this DI. 

“Annualization 2nd Year to 3rd Year” is the cost 

difference for a new position from the second

year to the journeyman level of that position. 

For example, the DI that was hired in FY 2011 

will cost $141,656 in FY 2012, based on the 

cost module. The journeyman level for this DI 

is estimated to cost $194,027 as reflected in 

the third year in the FY 2011 cost module. 
Proposed New Registrant Fee Schedule Calculations 2/1/2011

32

Historical Modular Costs are used to determine cost changes over time. Compound Annual 

Growth Rate (CAGR) is calculated for each job category for first year 50 %, second year, and 

third year.

Assumed staffing levels from Appendix 2 are applied to the Cost Module Summary to calculate 

50% lapse, Annualization 50% to 2nd Year, and Annualization 2nd Year to 3rd Year for each job 

category for FY 2012, FY 2013, and FY 2014. (See table below.) 

First Year 50%

FY 2008* FY2009* FY 2009 FY 2010 FY 2011 FY 2012 CAGR

SA 204,230 203,691 203,691 228,326 234,840 235,641 3.64%

DI 132,826 133,422 133,422 140,360 146,045 136,884 0.76%

I A 101,975 106,111 106,111 115,179 122,852 120,887 4.34%

CH 238,756 247,092 247,092 245,825 251,165 247,471 0.90%

AT 108,417 110,192 110,192 116,501 124,409 120,506 2.68%

ITS 174,492 181,743 181,743 192,396 182,192 172,627 -0.27%

PA 61,677 62,681 62,681 67,211 72,329 67,871 2.42%

TC 53,990 55,038 55,038 59,522 64,477 59,638 2.52%

Average 2.12%

2nd Year

FY 2008* FY2009* FY 2009 FY 2010 FY 2011 FY 2012

SA 193,224 200,836 207,509 213,829 222,864 220,851 3.40%

DI 126,086 128,119 134,792 134,257 141,656 134,420 1.61%

I A 122,498 130,552 137,225 142,716 146,629 142,132 3.79%

CH 157,381 165,613 185,962 164,775 174,816 173,471 2.46%

AT 194,868 201,478 208,151 210,428 223,484 217,016 2.73%

ITS 124,289 144,917 151,590 152,191 157,464 141,171 3.24%

PA 92,106 95,048 101,721 99,967 106,909 99,850 2.04%

TC 78,501 81,020 87,693 85,513 92,369 86,017 2.31%

Average 2.70%

3rd Year

FY 2008* FY2009* FY 2009 FY 2010 FY 2011 FY 2012

SA 255,624 265,655 272,328 280,740 290,318 289,061 3.12%

DI 171,269 175,247 181,920 183,413 194,027 184,119 1.83%

I A 167,681 177,680 184,353 191,872 199,000 191,831 3.42%

CH 202,564 212,741 233,090 213,931 227,187 223,170 2.45%

AT 194,868 201,478 208,151 210,428 223,484 217,016 2.73%

ITS 173,106 203,826 210,499 213,635 222,927 200,479 3.74%

PA 137,289 142,176 148,849 149,123 159,280 149,549 2.16%

TC 78,501 81,020 87,693 85,513 92,370 86,017 2.31%

Average 2.72%

* GSA Rent was excluded from the Cost Module calculation starting FY 2010.

FY2008 and FY2009 Cost Modules were adjusted to remove GSA Rent.
Proposed New Registrant Fee Schedule Calculations 2/1/2011

33

Estimated Cost of On-board Staffing Changes

FY2010 FY2011 FY2012 FY2013 FY2014

SA Increase 34 10 60 18 -

50% Lapse 16,670,100 5,183,132 -

Annualization 50% Lapse to 2nd Yr 139,605 673,560 182,353

Annualization 2nd Yr to 3rd Yr - - -

DI Increase (10) 64 40 - -

50% Lapse 5,475,360 - -

Annualization 50% Lapse to 2nd Yr (280,896) (98,560) -

Annualization 2nd Yr to 3rd Yr (491,560) 3,351,744 1,987,960

IA Increase (7) 1 - 26 2

50% Lapse - 3,279,627 263,240

Annualization 50% Lapse to 2nd Yr 23,777 - 555,731

Annualization 2nd Yr to 3rd Yr (344,092) 52,371 -

CH Increase 1 3 - 4 8

50% Lapse - 998,796 2,015,577

Annualization 50% Lapse to 2nd Yr (229,047) - (287,819)

Annualization 2nd Yr to 3rd Yr 49,156 157,113 -

AT Increase 3 (2) - 3 -

50% Lapse - 371,200 -

Annualization 50% Lapse to 2nd Yr (198,150) - 297,607

Annualization 2nd Yr to 3rd Yr - - -

IT Increase - - - 2 2

50% Lapse - 344,328 343,404

Annualization 50% Lapse to 2nd Yr - - (52,851)

Annualization 2nd Yr to 3rd Yr - - -

PA Increase 22 (1) - 30 -

50% Lapse - 2,085,431 -

Annualization 50% Lapse to 2nd Yr (34,580) - 971,139

Annualization 2nd Yr to 3rd Yr 1,081,432 (52,371) -

TC Increase 10 (2) - 28 -

50% Lapse - 1,711,920 -

Annualization 50% Lapse to 2nd Yr (55,784) - 752,244

Annualization 2nd Yr to 3rd Yr - (2) -

SL Increase 58 - - 62 -

50% Lapse - 5,420,771 -

Annualization 50% Lapse to 2nd Yr - - (429,481)

Annualization 2nd Yr to 3rd Yr (24,541) - -

Contractor Increase 22 2 - 16 -

1st Yr - 776,685 -

Annualization 1st Yr to 2nd Yr 90,780 - 776,685

Annualization 2nd Yr to 3rd Yr - - -

Total

1st Yr (mostly 50% Lapse) 22,145,460 20,171,890 2,622,221

Annualization 50% Lapse to 2nd Yr (544,295) 575,000 2,765,609

Annualization 2nd Yr to 3rd Yr 270,395 3,508,855 1,987,960
Proposed New Registrant Fee Schedule Calculations 2/1/2011

34

Appendix 5: Target Operational Continuity Fund 

Unlike appropriated funds where approved budgets are assured by law, DEA collects registration 

fees, which are subject to fluctuations and uncertainty, to fund the activities of DCP. DEA 

maintains an operational continuity fund (OCF)10 based on the need to maintain DCP operations 

during historically low (or negative) collection periods. 

Specifically, the OCF serves two purposes:

1. Have sufficient funds at the beginning of the fiscal year to fund operations while the first $15

million in collections are paid to the Treasury.

2. Have sufficient funds to prevent fluctuations in collections from adversely affecting operations. 

(Without OCF, periods of lower than expected collection would require adjustment in 

operation/spending to prevent a negative balance.)

Since the $15 million is a constant amount specified in law that is needed at the beginning of 

each year, $15 million would be enough to satisfy purpose one above.

To determine the OCF needed to satisfy purpose two above, historical collections and obligations 

were examined. Tables below summarize the monthly collections and obligations as a percent of 

the total:

 

10 Often called “working capital” in industry, DEA avoids using this term to not cause confusion between OCF and 

a specific account “Working Capital Fund” maintained by DOJ.

Cumulative Net Obligations as % of Total Obligations

Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep

FY2004 9.27% 16.66% 20.62% 32.55% 38.64% 46.31% 53.56% 61.09% 69.62% 78.38% 88.06% 100.00%

FY2005 7.34% 12.76% 21.52% 28.83% 35.27% 45.84% 55.88% 64.38% 70.87% 83.04% 85.59% 100.00%

FY2006 8.51% 14.36% 25.49% 32.69% 42.17% 51.27% 59.73% 66.95% 74.02% 83.88% 92.71% 100.00%

FY2007 4.80% 12.57% 19.33% 25.62% 33.26% 42.87% 53.48% 60.53% 65.62% 72.54% 90.36% 100.00%

FY2008 4.91% 11.42% 16.30% 22.65% 29.62% 42.19% 48.32% 55.14% 74.84% 83.52% 92.21% 100.00%

FY2009 7.14% 12.34% 22.38% 28.94% 35.51% 41.10% 48.14% 58.73% 69.01% 77.34% 87.77% 100.00%

FY2010 5.02% 10.70% 19.24% 25.22% 33.48% 40.59% 51.85% 59.65% 72.99% 83.62% 89.23% 100.00%

Average 6.71% 12.97% 20.70% 28.07% 35.42% 44.31% 52.99% 60.92% 71.00% 80.33% 89.42% 100.00%

Minimum 4.80% 10.70% 16.30% 22.65% 29.62% 40.59% 48.14% 55.14% 65.62% 72.54% 85.59% 100.00%

Maximum 9.27% 16.66% 25.49% 32.69% 42.17% 51.27% 59.73% 66.95% 74.84% 83.88% 92.71% 100.00%

(Net Obligations = Obligations - Recoveries from Deobligation)

Cumulative Gross Collections as % of Total Gross Collections

Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep

FY04 2.12% 7.23% 14.90% 23.49% 31.96% 41.51% 49.01% 58.16% 71.19% 79.99% 91.20% 100.00%

FY05 4.77% 12.92% 21.51% 30.56% 37.89% 47.78% 55.43% 63.90% 72.82% 81.38% 90.80% 100.00%

FY06 6.01% 13.00% 20.49% 31.39% 40.71% 48.92% 56.72% 65.33% 74.54% 82.58% 91.90% 100.00%

FY07 4.90% 9.71% 16.75% 28.23% 37.64% 46.15% 54.02% 64.19% 73.10% 82.32% 91.71% 100.00%

FY08 6.48% 12.51% 21.67% 31.53% 40.52% 48.44% 56.17% 64.22% 72.90% 82.00% 91.09% 100.00%

FY09 6.84% 13.39% 19.32% 29.42% 39.87% 48.39% 55.76% 64.87% 73.97% 82.92% 91.26% 100.00%

FY10 6.10% 12.77% 20.55% 29.89% 38.96% 47.23% 55.77% 65.13% 73.89% 82.29% 91.36% 100.00%

Average 5.32% 11.65% 19.31% 29.22% 38.22% 46.92% 54.70% 63.68% 73.20% 81.92% 91.33% 100.00%

Minimum 2.12% 7.23% 14.90% 23.49% 31.96% 41.51% 49.01% 58.16% 71.19% 79.99% 90.80% 100.00%

Maximum 6.84% 13.39% 21.67% 31.53% 40.71% 48.92% 56.72% 65.33% 74.54% 82.92% 91.90% 100.00%

(Gross Collections = Registration Fees + Other Collections (sale of vehicles) + CMEA Self-certification Collections)
Proposed New Registrant Fee Schedule Calculations 2/1/2011

35

The tables show that there are times where obligations exceed collections. For example, in 

November FY 2004, cumulative obligations exceeded collections by 9.4 percent, or the 

cumulative balance (collections minus obligations) was -9.4 percent. This was an unusual year 

and operational adjustments were made to ensure DEA did not spend beyond funds that were 

available.

Therefore, OCF needs to be sufficient to cover the maximum difference between cumulative 

obligations and cumulative collections at any given month in the year.

Model historical data as a triangular probability distribution,

11 for example, in the month of 

November:

Cumulative Obligation

o Maximum: 16.66%

o Minimum: 10.70%

o Average/Mode: 12.97%.

Cumulative Collection

o Maximum: 13.39%

o Minimum: 7.23%

o Average/Mode: 11.65%

In a given year, there may have been instances where spending was altered due to low 

collections. Since the purpose of the OCF is to prevent adjusting operations/spending as a result 

of low collections, collections and obligations are modeled independently to prevent this 

relationship from influencing the model.

Using Monte-Carlo12 simulation (10,000 iterations), the maximum negative minimum balance 

(cumulative collections minus obligations) was determined. The table below is an example of 

one iteration. The minimum balance is -3.61 percent in April.

 

11 Triangular distribution in this example means that future cumulative collections in November will be at a 

minimum 7.23 percent, a maximum 13.39 percent, and most likely 11.65 percent.

12 Monte Carlo simulation (named after Monte Carlo, Monaco, where games of chance are a popular attraction) is 

an iterative method where variables are randomly varied according to the assumed probability distribution. Aided 

by a computer, numerous iterations (10,000 in this case) result in numerous outcomes. The results define the 

probability of different outcomes occurring.

Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep

Collections 4.25% 12.36% 21.03% 31.20% 37.33% 45.28% 51.66% 59.26% 73.75% 81.97% 91.31% 100.00%

Obligations 5.90% 13.49% 21.49% 28.10% 32.76% 41.61% 55.27% 60.14% 71.54% 76.62% 89.58% 100.00%

Collections-Obligations -1.65% -1.13% -0.46% 3.09% 4.57% 3.67% -3.61% -0.89% 2.21% 5.35% 1.73% 0.00%

Min Balance -3.61%
Proposed New Registrant Fee Schedule Calculations 2/1/2011

36

Results of the 10,000 iterations are summarized by the below probability density function. 

The results indicate that of the 10,000 iterations the lowest minimum balance is -9.64 percent, 

the highest minimum balance is 0.00 percent and on average the minimum balance is -4.47

percent. Also, 95 percent of the outcomes are above -7.00 percent, which means that only five

percent of the time the cumulative obligations were more than seven percent of cumulative 

collections. Alternatively, having a seven percent OCF has a 95 percent likelihood of being 

enough to fund DCP operations without operational adjustments as a result of fluctuations and 

differences between collections and obligations.

DEA has decided that the five percent risk of having to adjust operations as a result of month-tomonth fluctuations/differences in collections and obligations is a tolerable risk. Therefore, a

sufficient amount for purpose number two above is seven percent of planned obligations/budget.

Combining the two components of the OCF, Target OCF Balance is $15 million plus seven

percent of planned obligations.

Minimum -9.64%

Maximum 0.00%

Mean -4.47%

Std Dev 1.41%

Summary Statistics for 

Min Balance
Proposed New Registrant Fee Schedule Calculations 2/1/2011

37

Appendix 6: Estimated Number of Registration Fee Transactions

The estimated number of registration fee transactions is a forecast based on a ten year history of 

registration fee transactions.

Below is a summary of the forecasted number of registrations. Groups A, B, C, D, and M are on 

three year registration cycles. Thus the number of annual registration fee transactions is roughly 

one-third of the population of paying registrants.

Group Business Activity 2012 2013 2014 Total

3 year 

registration

A Pharmacy 25,462 23,050 25,901 74,413 

B Hospital/Clinic 4,456 4,553 4,647 13,656 

C Practitioner 376,425 366,802 382,390 1,125,617 

D Teaching Institution 81 68 73 222 

M Mid-level Practitioner (MLP) 70,821 72,309 79,037 222,167 

1 year registration

E Manufacturer 534 536 536 1,606 

F Distributor 713 718 722 2,153 

G Researcher/Canine Handler 4,181 4,308 4,440 12,929 

H Analytical Lab 902 898 895 2,695 

J Importer 212 214 216 642 

K Exporter 245 246 247 738 

L Reverse Distributor 65 66 67 198 

N Maintenance 178 180 181 539 

P Detoxification 78 78 78 234 

R Maintenance & Detox 875 888 900 2,663 

S Compounder/Maintenance 5 5 5 15 

T Compounder/Detoxification 1 1 1 3 

U Compounder/Maintenance/Detox 52 52 52 156 

W Chemical Manufacturer 228 232 235 695 

X Chemical Importer 185 186 187 558 

Y Chemical Distributor 387 290 217 894 

Z Chemical Exporter 177 180 183 540 

Total 486,263 475,860 501,210 1,463,333 

The forecasted number of registration fee transactions is based on the following mathematical 

expressions:

[New Registration Fee Transactions] + [Registration Renewal Transactions] = [Total Registration Fee 

Transactions]

Where, 

[Registration Renewal Transactions] = [Total Registration Fee Transactions, previous period] x 

[Retention Rate]
Proposed New Registrant Fee Schedule Calculations 2/1/2011

38

And, 

[Retention Rate] = average of historical (Registration Renewal Transactions divided by Total 

Registration Fee Transactions Previous Period)

“Previous Period” = 3 years for Business Activities on 3 year registrations, 1 year for Business 

Activities on 1 year registrations

The following steps were taken to generate the forecast (refer to detailed table below):

1. Get historical data

a. Query historical numbers for [New Registration Fee Transactions] and [Registration 

Renewal Transactions] by Registrant Group (Business Activity) for each of the 10 years.

b. Sum the two numbers to get [Total Registration Fee Transactions]

c. Calculate [Retention Rate] for each year by dividing the [Registration Renewal 

Transactions] by [Total Registration Fee Transactions, previous period].

d. Calculate [Average Retention Rate]

2. Forecast [New Registration Fee Transactions] for FY 201113 to FY 2014

a. Examine FY 2001 to FY 2010 [New Registration Fee Transactions] for any discernable 

trends.

i. Examination of the historical number of new registrants showed that some 

registrant groups had a well defined trend line (low scatter), while others did 

not (large scatter). Trend lines were used to project new registrants for 

registrant groups with well defined trend lines, while an average was used for 

registrant groups with large scatter. Although a trend line can be 

mathematically generated on a registrant group with large scatter, the 

confidence level on the trend line would be low.

ii. Additionally, trend lines for some groups changed over time. For the registrant 

groups that did have a noticeable change in new registrants, a five year history 

is used to not skew the data with data prior to the fee increase. For the 

registrant groups that did not have a noticeable drop in new registrants, ten 

year history is used.

b. If there is a discernible trend, use linear regression14 to develop trend line and 

forecast15 [New Registration Fee Transactions] for FY 2011 to FY 2014.

 

13 Need FY 2011 numbers to forecast FY 2012 to FY 2014 numbers.

14 Linear regression is a statistical approach used to calculate a straight line that best fits the data: historical number 

of new registration fee transactions by year. The calculated line is used to forecast the number of registration fee 

transactions for future years.

15 Used “FORECAST” function in MS Excel. From Microsoft Office Excel 2007 Help: “(FORECAST function) 

Calculates, or predicts, a future value by using existing values. The predicted value is a y-value for a given x-value. 

The known values are existing x-values and y-values, and the new value is predicted by using linear regression. You 

can use this function to predict future sales, inventory requirements, or consumer trends.”
Proposed New Registrant Fee Schedule Calculations 2/1/2011

39

c. If the trend is indiscernible, use average of FY 2001 to FY 2010 [New Registration Fee 

Transactions] to forecast [New Paying Registration] for FY 2011 to FY 2014.

d. Use five or ten years of data based on historical data examination in step 2.a.ii above. 

[New Registration Forecast Method] in the table below indicates whether five or ten

year history was used and whether a trend line or average was used to forecast [New 

Paying Registration] for FY 2011 to FY 2014.

3. Forecast [Registration Renewal Transactions] for FY 2011 to FY 2014

a. Use [Average Retention Rate] as the [Retention Rate] for years FY 2011 to FY 2014.

b. Multiply [Total Registration Fee Transactions, previous period] by [Retention Rate] for 

[Registration Renewal Transactions]

i. For groups A, B, C, D, M (Three year registrations):

[Total Registration Fee Transactions, FY 2008] * [Retention Rate, FY

2011] = [Registration Renewal Transactions, FY 2011]

ii. For all other groups (One year registrations):

[Total Registration Fee Transactions, FY 2008] * [Retention Rate, FY

2011] = [Registration Renewal Transactions, FY 2011]

4. Forecast [Total Registration Fee Transactions] for FY 2011 to FY 2014

a. Sum [New Registration Fee Transactions, FY 2011] from step 2 and [Paying Renewal, FY

2011] from step 3 for [Total Registration Fee Transactions, FY 2011]

b. Repeat steps 3 and 4.a for years: FY 2012, FY 2013, and FY 2014 for [Total Registration 

Fee Transactions] for FY 2013 to FY 2014.
40

Group 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Average 

Renewal 

Rate

New 

Registration 

forecast method

A New Registration Fee Transactions 3980 4044 4251 3922 4246 4058 3628 3710 4217 3,249 3,626 3,570 3,515 3,459 10-yr trend

Registration Renewal Transactions 12123 18567 17862 13982 19362 18147 16336 20783 20490 18,798 21,702 21,892 19,535 22,442

Renewal Rate 86.8% 85.6% 82.1% 91.2% 88.0% 92.3% 94.2% 88.6% 88.6% 88.6% 88.6% 88.6%

Total Registration Fee Transactions 16103 22611 22113 17904 23608 22205 19964 24493 24707 22047 25,328 25,462 23,050 25,901

B New Registration Fee Transactions 809 851 1158 1169 1073 1087 932 934 838 879 973 973 973 973 10-yr ave

Registration Renewal Transactions 2742 2809 2748 2947 3041 3194 3298 3369 3421 3,498 3,519 3,483 3,580 3,674

Renewal Rate 83.0% 83.1% 81.8% 80.1% 81.9% 79.9% 82.7% 81.8% 81.8% 81.8% 81.8% 81.8%

Total Registration Fee Transactions 3551 3660 3906 4116 4114 4281 4230 4303 4259 4377 4,492 4,456 4,553 4,647

C New Registration Fee Transactions 38109 39300 44238 41635 41596 41921 40805 44209 45525 46,588 46,312 47,024 47,737 48,450 10-yr trend

Registration Renewal Transactions 249118 261141 261625 262698 275216 282010 282560 294554 309873 297,658 313,983 329,401 319,065 333,940

Renewal Rate 91.9% 91.5% 91.6% 92.2% 92.8% 93.0% 95.7% 92.1% 92.7% 92.7% 92.7% 92.7% 92.7%

Total Registration Fee Transactions 287227 300441 305863 304333 316812 323931 323365 338763 355398 344246 360,295 376,425 366,802 382,390

D New Registration Fee Transactions 13 15 39 38 36 43 49 33 27 3 4 33 33 33 33 10-yr ave

Registration Renewal Transactions 18 31 63 20 32 61 35 34 59 2 8 38 48 35 40

Renewal Rate 64.5% 69.6% 59.8% 60.3% 50.0% 56.7% 33.3% 56.3% 56.3% 56.3% 56.3% 56.3%

Total Registration Fee Transactions 31 46 102 58 68 104 84 67 86 62 71 81 68 73

M New Registration Fee Transactions 12605 12136 14279 13803 14406 16346 15431 17292 17830 18,484 19,079 19,747 20,414 21,082 5-yr trend

Registration Renewal Transactions 9699 12438 15925 18226 21047 27664 29422 34072 39389 39,654 45,848 51,074 51,895 57,955

Renewal Rate 81.7% 85.6% 91.6% 91.9% 96.1% 89.5% 88.4% 89.3% 89.3% 89.3% 89.3% 89.3%

Total Registration Fee Transactions 22304 24574 30204 32029 35453 44010 44853 51364 57219 58138 64,927 70,821 72,309 79,037

E New Registration Fee Transactions 47 46 72 71 77 66 67 61 54 6 3 57 55 53 51 5-yr trend

Registration Renewal Transactions 301 313 329 347 438 442 444 448 402 460 473 479 483 485 

Renewal Rate 89.9% 91.6% 86.5% 104.8% 85.8% 87.4% 87.7% 79.0% 100.9% 90.4% 90.4% 90.4% 90.4% 90.4%

Total Registration Fee Transactions 348 359 401 418 515 508 511 509 456 523 530 534 536 536 

F New Registration Fee Transactions 85 139 132 127 153 139 113 94 82 7 0 113 113 113 113 10-yr ave

Registration Renewal Transactions 560 536 535 563 672 652 638 639 600 630 594 600 605 609 

Renewal Rate 83.1% 79.3% 84.4% 97.4% 79.0% 80.7% 85.1% 81.9% 92.4% 84.8% 84.8% 84.8% 84.8% 84.8%

Total Registration Fee Transactions 645 675 667 690 825 791 751 733 682 700 707 713 718 722 

G New Registration Fee Transactions 474 442 544 493 583 555 581 677 585 704 696 720 744 768 10-yr trend

Registration Renewal Transactions 2762 2737 2706 2753 2790 2828 2846 2918 2817 3,243 3,364 3,461 3,564 3,672 

Renewal Rate 86.9% 84.6% 85.1% 84.7% 86.0% 83.8% 84.1% 85.1% 78.4% 95.3% 85.2% 85.2% 85.2% 85.2% 85.2%

Total Registration Fee Transactions 3236 3179 3250 3246 3373 3383 3427 3595 3402 3947 4,060 4,181 4,308 4,440 

H New Registration Fee Transactions 61 74 98 105 90 95 87 80 103 110 90 90 90 90 10-yr ave

Registration Renewal Transactions 784 759 737 719 731 729 737 740 661 801 816 812 808 805 

Renewal Rate 89.8% 88.5% 86.1% 88.7% 88.8% 89.4% 89.8% 80.6% 104.8% 89.6% 89.6% 89.6% 89.6% 89.6%

Total Registration Fee Transactions 845 833 835 824 821 824 824 820 764 911 906 902 898 895 

J New Registration Fee Transactions 20 21 32 38 34 40 33 28 36 3 1 31 31 31 31 10-yr ave

Registration Renewal Transactions 102 118 121 130 142 146 152 157 148 175 178 181 183 185 

Renewal Rate 96.7% 87.1% 85.0% 84.5% 83.0% 81.7% 84.9% 80.0% 95.1% 86.4% 86.4% 86.4% 86.4% 86.4%

Total Registration Fee Transactions 122 139 153 168 176 186 185 185 184 206 209 212 214 216 

K New Registration Fee Transactions 31 28 30 27 56 33 29 36 27 3 1 33 33 33 33 10-yr ave

Registration Renewal Transactions 177 179 192 192 185 192 200 197 190 211 211 212 213 214 

Renewal Rate 86.1% 92.8% 86.5% 84.5% 79.7% 88.9% 86.0% 81.5% 97.2% 87.0% 87.0% 87.0% 87.0% 87.0%

Total Registration Fee Transactions 208 207 222 219 241 225 229 233 217 242 244 245 246 247 

(Continued on next page)
Proposed New Registrant Fee Schedule Calculations 2/1/2011

41

(Continued from previous page)

Group 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Average 

Renewal 

Rate

New 

Registration 

forecast method

L New Registration Fee Transactions 2 1 5 6 4 13 7 10 19 14 8 8 8 8 10-yr ave

Registration Renewal Transactions 30 33 36 40 39 38 37 38 36 49 56 57 58 59 

Renewal Rate 103.1% 105.9% 97.6% 84.8% 88.4% 72.5% 86.4% 75.0% 89.1% 89.2% 89.2% 89.2% 89.2% 89.2%

Total Registration Fee Transactions 32 34 41 46 43 51 44 48 55 63 64 65 66 67 

N New Registration Fee Transactions 8 15 21 24 35 26 48 15 25 20 24 24 24 24 10-yr ave

Registration Renewal Transactions 88 91 90 105 104 110 114 128 128 154 152 154 156 157 

Renewal Rate 94.8% 84.9% 94.6% 80.6% 79.1% 83.8% 79.0% 89.5% 100.7% 87.4% 87.4% 87.4% 87.4% 87.4%

Total Registration Fee Transactions 96 106 111 129 139 136 162 143 153 174 176 178 180 181 

P New Registration Fee Transactions 17 12 10 20 16 9 10 5 8 12 12 12 12 12 10-yr ave

Registration Renewal Transactions 95 98 97 84 81 76 76 72 66 66 66 66 66 66 

Renewal Rate 87.5% 88.2% 78.5% 77.9% 78.4% 89.4% 83.7% 85.7% 89.2% 84.3% 84.3% 84.3% 84.3% 84.3%

Total Registration Fee Transactions 112 110 107 104 97 85 86 77 74 78 78 78 78 78 

R New Registration Fee Transactions 54 65 56 80 98 101 88 69 63 57 73 73 73 73 10-yr ave

Registration Renewal Transactions 584 598 624 654 666 697 709 744 677 789 788 802 815 827 

Renewal Rate 93.7% 94.1% 96.2% 90.7% 91.2% 88.8% 93.4% 83.3% 106.6% 93.1% 93.1% 93.1% 93.1% 93.1%

Total Registration Fee Transactions 638 663 680 734 764 798 797 813 740 846 861 875 888 900 

S New Registration Fee Transactions 2 0 0 0 6 1 0 1 0 - 1 1 1 1 10-yr ave

Registration Renewal Transactions 4 5 5 5 5 7 8 5 5 5 4 4 4 4 

Renewal Rate 83.3% 100.0% 100.0% 100.0% 63.6% 100.0% 62.5% 83.3% 100.0% 88.1% 88.1% 88.1% 88.1% 88.1%

Total Registration Fee Transactions 6 5 5 5 11 8 8 6 5 5 5 5 5 5 

T New Registration Fee Transactions 0 0 1 0 0 1 1 0 1 - - - - - 10-yr ave

Registration Renewal Transactions 4 4 3 2 1 1 1 1 0 1 1 1 1 1 

Renewal Rate 100.0% 75.0% 50.0% 50.0% 50.0% 50.0% 62.5% 62.5% 62.5% 62.5% 62.5%

Total Registration Fee Transactions 4 4 4 2 1 2 2 1 1 1 1 1 1 1 

U New Registration Fee Transactions 2 2 4 4 5 12 5 3 4 4 5 5 5 5 10-yr ave

Registration Renewal Transactions 63 64 61 60 60 61 50 52 47 48 47 47 47 47 

Renewal Rate 98.5% 92.4% 92.3% 93.8% 93.8% 68.5% 94.5% 85.5% 94.1% 90.4% 90.4% 90.4% 90.4% 90.4%

Total Registration Fee Transactions 65 66 65 64 65 73 55 55 51 52 52 52 52 52 

W New Registration Fee Transactions 24 34 45 48 50 23 63 50 41 36 44 44 45 45 5-yr trend

Registration Renewal Transactions 147 162 171 182 181 185 149 145 143 183 180 184 187 190 

Renewal Rate 94.7% 87.2% 84.3% 78.7% 80.1% 71.6% 68.4% 73.3% 99.5% 82.0% 82.0% 82.0% 82.0% 82.0%

Total Registration Fee Transactions 171 196 216 230 231 208 212 195 184 219 224 228 232 235 

X New Registration Fee Transactions 22 56 40 40 42 26 40 33 35 26 36 36 36 36 10-yr ave

Registration Renewal Transactions 121 126 135 149 155 154 130 134 120 156 148 149 150 151 

Renewal Rate 88.1% 74.2% 85.1% 82.0% 78.2% 72.2% 78.8% 71.9% 100.6% 81.2% 81.2% 81.2% 81.2% 81.2%

Total Registration Fee Transactions 143 182 175 189 197 180 170 167 155 182 184 185 186 187 

Y New Registration Fee Transactions 272 275 440 396 266 136 181 140 105 50 44 11 - - 10-yr trend

Registration Renewal Transactions 2172 2099 2098 2029 1944 1662 872 673 565 559 457 376 290 217 

Renewal Rate 85.9% 88.4% 79.9% 80.2% 75.2% 48.5% 63.9% 69.5% 83.4% 75.0% 75.0% 75.0% 75.0% 75.0%

Total Registration Fee Transactions 2444 2374 2538 2425 2210 1798 1053 813 670 609 501 387 290 217 

Z New Registration Fee Transactions 21 37 33 26 41 17 50 20 12 16 27 27 27 27 10-yr ave

Registration Renewal Transactions 116 126 135 149 157 151 134 128 111 153 146 150 153 156 

Renewal Rate 92.0% 82.8% 88.7% 89.7% 76.3% 79.8% 69.6% 75.0% 124.4% 86.5% 86.5% 86.5% 86.5% 86.5%

Total Registration Fee Transactions 137 163 168 175 198 168 184 148 123 169 173 177 180 183 

 56,658 57,593 65,528 62,072 62,913 64,748 62,248 67,500 69,637 70,478 71,317 72,630 73,967 75,314

281,810 303,034 306,298 306,036 327,049 339,207 338,948 360,031 379,948 367,319 392,771 413,633 401,893 425,896

338,468 360,627 371,826 368,108 389,962 403,955 401,196 427,531 449,585 437,797 464,088 486,263 475,860 501,210

Sum of New Registration Fee Transactions

Sum of Registration Renewal Transactions

Sum of Total Registration Fee Transactions
42

Appendix 7: Collections Estimates Based on Proposed Fee

The number of registration fee transactions by registrant group in Appendix 6 is summarized in 

the left portion of the table below. Multiply each of the groups by the proposed fee for that 

group for each of the years to calculate estimated collections from proposed fees for each of the 

registrant groups for each of the years. The sum represents estimated total collections by year.

Proposed 

Fee

Group 2012 2013 2014 2012-2014 Group 2012 2013 2014

A 25,462 23,050 25,901 $ 732 A $ 18,638,184 $ 16,872,600 $ 18,959,532

B 4,456 4,553 4,647 $ 732 B $ 3,261,792 $ 3,332,796 $ 3,401,604

C 376,425 366,802 382,390 $ 732 C $ 275,543,100 $ 268,499,064 $ 279,909,480

D 81 68 73 $ 732 D $ 59,292 $ 49,776 $ 53,436

M 70,821 72,309 79,037 $ 732 M $ 51,840,972 $ 52,930,188 $ 57,855,084

E 534 536 536 $ 3,052 E $ 1,629,768 $ 1,635,872 $ 1,635,872

F 713 718 722 $ 1,526 F $ 1,088,038 $ 1,095,668 $ 1,101,772

G 4,181 4,308 4,440 $ 244 G $ 1,020,164 $ 1,051,152 $ 1,083,360

H 902 898 895 $ 244 H $ 220,088 $ 219,112 $ 218,380

J 212 214 216 $ 1,526 J $ 323,512 $ 326,564 $ 329,616

K 245 246 247 $ 1,526 K $ 373,870 $ 375,396 $ 376,922

L 65 66 67 $ 1,526 L $ 99,190 $ 100,716 $ 102,242

N 178 180 181 $ 244 N $ 43,432 $ 43,920 $ 44,164

P 78 78 78 $ 244 P $ 19,032 $ 19,032 $ 19,032

R 875 888 900 $ 244 R $ 213,500 $ 216,672 $ 219,600

S 5 5 5 $ 244 S $ 1,220 $ 1,220 $ 1,220

T 1 1 1 $ 244 T $ 244 $ 244 $ 244

U 52 52 52 $ 244 U $ 12,688 $ 12,688 $ 12,688

W 228 232 235 $ 3,052 W $ 695,856 $ 708,064 $ 717,220

X 185 186 187 $ 1,526 X $ 282,310 $ 283,836 $ 285,362

Y 387 290 217 $ 1,526 Y $ 590,562 $ 442,540 $ 331,142

Z 177 180 183 $ 1,526 Z $ 270,102 $ 274,680 $ 279,258

 486,263 475,860 501,210 Total $ 356,226,916 $ 348,491,800 $ 366,937,230

Estimated Collections from Proposed Registration 

Fee

Number of Registration Fee 

Transactions