Friday, March 14, 2008

Medicaid "Tamper Proof" Prescription Requirements - April 1, 2008

Medicaid "Tamper Proof" Prescription Requirement Effective April 1, 2008 As you know, last September the ADA, working with a coalition of organizations, fought for a six-month delay in the implementation of the requirement that Medicaid providers use tamper-resistant prescription pads.
With the April 1, 2008 start date nearing, we wanted to make sure that you are in a position to answer questions that may come from dentists and
patients in your state about this new requirement. Some key points:

1. As of April 1, 2008 a prescription pad must contain a security feature with at least one of the following three characteristic categories:

. One or more industry recognized features designed to prevent unauthorized copying.
. One or more industry recognized features designed to prevent the modification of information.
. One or more industry recognized features designed to prevent the use of counterfeit prescriptions.
2. By October 1, 2008, a prescription must contain all three security features. This includes computer-generated prescriptions that are printed using paper inserted into a printer. Please note that electronic prescriptions, faxed prescriptions and prescriptions sent over the telephone are exempt from this requirement.

3. There is NO national standard. CMS has deferred to the states to define the features that they will accept for a prescription to be considered tamper-resistant. With such potential variation, the National Association of State Medicaid Directors has compiled all state and federal guidance on its website at http://www.nasmd.org/issues/TRPP.asp. If your state requirements are not listed, it is recommended that you contact your State Medicaid Director to encourage additional clarification for prescribers, pharmacists and beneficiaries.

4. Other sources of information include:

a. American Pharmacists Association (APhA),
<http://www.pharmacist.com/am/template.cfm?Section=Home2>
b. National Association of Chain Drug Stores (NACDS)
<http://www.nacds.org/>
c. National Community Pharmacists Association (NCPA).
<http://www.ncpanet.org/>

NCPA developed educational materials for prescribers, pharmacists and beneficiaries that are available on the National Council for Prescription Drug Programs (NCPDP) website at: http://www.ncpdp.org/pdf/Tamper_resistant_
. This link also includes recommendations to State Medicaid Directors for tamper-resistant prescription pad features as well as other materials.

5. One last source of information may be your state dental director. You
already know them, but for easy access click on the link:
http://www.astdd.org/index.php?template=memberslist.php

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