On March 21, 2005, WLF filed formal comments with the Drug Enforcement Administration (DEA), urging that DEA regulation of pain medication not create a risk of denying needed pain medicines to terminally ill patients and chronic pain patients. In response to DEA’s plan to issue new guidance regarding dispensing of controlled substances, WLF emphasized the importance of granting physicians leeway in treating bona fide pain patients, and that physicians should not be at risk of prosecution unless they distribute or prescribe controlled substances to a person outside the scope of legitimate practice. In separate comments filed the same day, WLF also expressed concern that DEA’s new mandate to withhold approval for procurement of controlled substances used in the production of pain medicines should not be used by DEA to second-guess FDA approval decisions. WLF argued that DEA’s role in this regard is advisory and that Congress has vested drug approval authority with FDA.