Tamper-Resistant Prescriptions: CMS and MassHealth Guidelines

Effective July 1, 2013, all paper prescriptions in Massachusetts must be written on pads that contain at least one industry-recognized feature to prevent copying, erasing, or counterfeiting.

The characteristics of these pads must be consistent with Medicaid's requirements for tamper-proof prescription pads:

Tamper-Resistant Characteristics

CMS Characteristics
MassHealth Suggested Features
Prevent unauthorized copying of a completed or blank prescription form
Use of a latent, repetitive, printed word "VOID" that will appear across the front of the prescription if it is scanned or photocopied. This feature must be patterned in such a way as not to obscure prescribing information
Prevent erasure or modification of information written on the prescription by the prescriber
Erasure protection, such that the prescription has a background that resists alteration and erasure (e.g., special security paper)
Prevent the use of counterfeit prescription forms
A heat-sensitive feature that will either change color or disappear and then reappear when rubbed (e.g., sensing imprint or thermochromic ink)

In addition, MassHealth recommends including a warning band that describes the security features on the prescription to make it easier for pharmacists to notice that your prescription is tamper resistant. Prescriptions must also continue to meet all other requirements of federal and state laws and regulations.

Source: MassHealth

Complying with the Regulation

  • Locate a vendor. Your current vendor may be able to provide secure pads for you.
  • In the event a compliant prescription must be written and the new pads are not available, fax or phone the script in.
  • A proactive approach might include exploring e-prescribing, which can often be provided free and is one of the exceptions provided.

Computer-Generated Prescriptions

MassHealth has received requests for additional guidance on computer-generated prescriptions using sequentially numbered blanks and barcodes to meet the tamper-resistant requirements. After a recent discussion with CMS, MassHealth has approved the following features to satisfy the tamper-resistant prescription requirement.

Feature
Description
Quantity border and fill (for computer-generated prescriptions on paper only)
Quantities are surrounded by special characters, such as an asterisk, to prevent alteration, e.g. QTY **50**. Values may also be expressed as text, e.g., (FIFTY).
Refill border and fill (for computer-generated prescriptions on paper only)
Refill quantities are surrounded by special characters, such as an asterisk, to prevent alteration, e.g. QTY **5**. Values may also be expressed as text, e.g., (FIVE).
Quantity check-off boxes
In addition to the written quantity on the prescription, quantities are indicated in ranges. It is recommended that ranges be in increments of 25, with the highest range being "151 and over." The box corresponding to the quantity prescribed MUST be checked for the prescription to be valid.

Source: MassHealth

Exceptions

  • Electronically delivered prescriptions, including faxed, e-prescribed and telephone scripts.
  • Prescriptions provided in institutional or clinical settings where the prescription is reimbursed as part of a bundled payment rate

Some Vendors to Consider

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