CMS Clarifies Medicaid Prescription Rule

The Centers for Medicare and Medicaid Services (CMS) previously said prescriptions printed from electronic medical records (EMRs) or e-prescribing applications would need special copy-resistant paper to comply with the tamper-resistant prescription pad regulation that takes effect Oct. 1. 

CMS now says such prescriptions may be printed on plain paper. For prescriptions to be considered tamper-resistant by CMS, the federal law specifies that the pad must meet all of the following characteristics by Oct. 1:

  • Prevent unauthorized copying of completed or blank prescription forms,
  • Prevent erasure or modification of information written on the prescription form, and
  • Prevent the use of counterfeit prescription forms.

CMS has identified at least two features that can be incorporated into computer-generated prescriptions printed on plain paper to prevent passing a copied prescription as an original prescription. One feature would be the use of a very small font that is readable when viewed at 5x magnification or greater and illegible when copied. Another feature would be a "void" pantograph accompanied by a reverse "Rx," which causes a word such as "Void" to appear when the prescription is photocopied.

The National Council for Prescription Drug Programs has developed guidance and examples of best practices and examples of tamper-resistant prescriptions (handwritten and EMR generated).

The Texas Tamper-Resistant Prescription Pad was  recently revised  [ PDF ] after CMS issued its clarification.

Action , Sept. 15, 2008


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