Tamper-Resistant Prescription Drug Pads
Effective April 1, 2008, a prescription written for a Medicaid recipient must contain at least one tamper resistant feature explained below.
Effective October 1, 2008, prescriptions will be required to have a minimum of one feature from all three CMS categories of tamper resistant features.
The statute states that all written prescriptions must be “executed on a tamper-resistant pad.” As a result CMS has determined that features added to the prescription after they are printed do not meet the requirement of the statute (ex. gel ink). Features that would make the prescription tamper-resistant include certain types of paper as well as certain items that can be preprinted on the paper.
CMS further clarified that computer generated prescriptions printed by a provider on plain paper, including Electronic Medical Record (EMR) computer generated prescriptions, may meet CMS guidance by containing one or more industry-recognized features designed either to prevent the erasure or modification of information contained on the prescription, or to prevent the use of counterfeit prescription forms. However, based on CMS’ understanding of current prescription security technology, they do not believe that computer generated prescriptions printed by a prescriber on plain paper will be able to meet the requirement that prescriptions contain one or more industry recognized features designed to prevent unauthorized copying of a completed or blank prescription form.
Review of CMS Requirements
Therefore, beginning October 1, 2008, computer generated prescriptions must be printed on paper that meets that requirement.
By April 1, 2008, a prescription pad/paper must contain a feature within at least one
of the following three characteristic categories. CMS has stated that these requirements also apply to computer-generated prescriptions printed using paper inserted into the printer.
- One or more industry-recognized features designed to prevent unauthorized copying of a completed or blank prescription form.
- One or more industry-recognized features designed to prevent the erasure or modification of information written on the prescription by the prescriber.
- One or more industry-recognized features designed to prevent the use of counterfeit prescription forms.
By October 1, 2008, a prescription pad/paper must contain at least one feature in each of the three categories above.
Category 1: Prevent the unauthorized copying of a completed or blank prescription form. (Features in bold tend to be less costly and easier to implement.)
- “Void” or “Illegal” Pantograph
The word “Void”, “Copy” or “Illegal” appears when the prescription is photocopied. On faxed prescriptions, this feature requires the pharmacy to document if the prescription was faxed.
- Coin-reactive ink that changes color when rubbed by a coin.
- Watermark: Special paper containing a “watermark”.
- Micro printing: Very small font writing, such as a signature line.
Category 2: Prevent the erasure or modification of information written on the prescription by the prescriber.
- Uniform non-white background color
Background consists of a solid color or consistent pattern that has been printed onto the paper. This will inhibit a forger from physically erasing written or printed information on a prescription form. If someone tries to erase or copy, the consistent background color will look altered and show the color of the underlying paper.
- Quantity check off boxes in addition to the written quantity on the prescription
Quantities are indicated in ranges. It is recommended that ranges be 25’s with the highest being “151 and over”. The range box corresponding to the quantity prescribed MUST be checked for the prescription to be valid.
- Pre-print refill indicator (circle or check number of refills or “NR”)
Indicate the number of refills on the prescription. Refill number must be used to be a valid prescription.
- Pre-print “Rx is void if more than___ Rxs on paper” on prescription paper
This feature reduces the ability to add medications to the prescription. This line must be completed for this feature to be valid. Computer printer paper can accommodate this feature by printing “This space intentionally left blank” in an empty space or quadrant.
- Quantity Border (for computer generated prescriptions)
Quantities are surrounded by special characters such as an asterisk to prevent alteration, e.g. QTY **50**.
- Refill Border (for computer generated prescriptions)
Refill quantities are surrounded by special characters such as an asterisk to prevent alteration, e.g. QTY **5**.
- Chemically reactive paper
If exposed to chemical solvents, oxidants, acids, or alkalis the prescription paper will react and leave a mark visible to the pharmacist.
- Paper toner fuser: Special printer toner establishes a strong bond to prescription paper
- Safety or security paper with colored pattern: White (or some other color) mark appears when erased.
Category 3: Prevent the use of counterfeit prescription forms.
- Security features and descriptions listed on prescriptions
Complete list of the security features on the prescription paper for compliance purposes. This is recommended to aid pharmacists in identification of features implemented on prescription.
- Serial numbered prescriptions
- Bar code: Serial number is encoded in a bar code.
- Logos: Sometimes used as part of the background color or pantograph.
- Metal strip: Paper contains metal security strip.
- Heat sensing imprint: By touching the imprint or design, the imprint will disappear.
- Paper contains fibers or ink visible only under black light.
- Thermochromic ink: Changes color when exposed to heat and then changes back to its original color when cooled. When an area of a document is printed with thermochromic ink, it can easily be tested for authenticity by holding or rubbing the area between fingers to activate the color change. This property cannot be reproduced by a copier.
- Holograms that interfere with photocopying
Tamper-Resistant Prescription Pad Vendors
South Dakota Medicaid is aware of the following vendors who claim to provide tamper-resistant prescription pad. Specific vendors or products cannot be endorsed or recommended.
- This requirement applies to all non-electronic prescriptions written for SD Medicaid recipients when SD Medicaid is the primary or secondary payer.
- Drug Enforcement Administration and South Dakota Board of Pharmacy laws and regulations pertaining to written and electronic prescriptions still apply.
- SD Medicaid will not endorse specific vendors that supply tamper-resistant pads.
- Medical practitioners who prescribe drugs to Medicaid recipients are responsible for obtaining the tamper-resistant prescription pads and/or printer paper.
- Prescribers not utilizing compliant pads or printer paper should anticipate additional telephone calls or faxes from pharmacies to obtain compliant prescriptions.
Exempt from the tamper-resistant requirement are prescriptions that are:
- Faxed to the pharmacy from the provider’s office.
- Telephoned to the pharmacy by the provider.
- Refills for which the original prescription was filled before April 1, 2008.
Links and Other Resources