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Effective April 1, 2008, the federal government (CMS) will require that all prescriptions provided on behalf of Medicaid patients covered by traditional Medicaid be written on tamper-resistant prescription pads. The prescriptions are required to have, at a minimum, a single tamper-resistant feature. This requirement will not currently apply to Medicaid recipients covered by any Medicaid managed care plan.
Listed below is a short synopsis of what physicians and their staff may expect once this requirement is in full effect on April 1, 2008:
Overview of tamper resistant prescription pad law
In order for Medicaid outpatient drugs to be reimbursable by the federal government, all written, non-electronic prescriptions must be executed on tamper-resistant pads. To be considered tamper resistant a prescription pad must contain at least one of the following:
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one or more industry-recognized features designed to prevent unauthorized copying of a completed or blank prescription form;
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one or more industry-recognized features designed to prevent the erasure or modification of information written on the prescription by the prescriber; or
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one or more industry-recognized features designed to present the use of counterfeit prescription forms.
Beginning October 1, 2008, a prescription pad/paper must contain at least one feature in each of the three categories listed above. In addition, beginning October 1, computer-generated prescriptions must be printed on paper that meets the above requirements. In addition, at a point one year after the implementation date, in order for prescriptions pads to be considered tamper resistant, a prescription pad must contain all three of the foregoing characteristics.
The requirement, once implemented, will apply to:
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All written prescriptions presented at the pharmacy on or after the published implementation date regardless of when the prescription was written;
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Written prescriptions for all outpatient drugs, including controlled, non-controlled, and over-the-counter drugs;
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Written prescriptions for drugs provided in a long-term care facility;
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Written prescriptions when Medicaid pays any part of the claim, including when Medicaid is not the primary payer, and
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Written prescriptions billed to Medicaid after the date of service due to retroactive eligibility.
The requirement, once implemented, DOES NOT apply to:
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Orders for medications administered in a provider setting (e.g., physician office or hospital outpatient or emergency department) and billed by the administering provider.
Refills of written prescriptions presented at a pharmacy before the implementation date;
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Electronic, faxed or telephoned prescriptions; and
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Prescriptions for which payment will be made by a Medicaid managed care entity (i.e., this requirement applies only to prescriptions written for patients who receive a monthly paper Ohio Medicaid card, not to prescriptions written for patients enrolled in a Medicaid managed health care organization)
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Physician offices are NOT exempt
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In addition, prescriptions will be covered if the physician provides the pharmacy with a verbal, faxed, electronic, or tamper-resistant written prescription within 72 hours of the date the prescription was filled.
Physicians interested in obtaining compliant prescription pads may contact the AMCNO for more information.
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