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CMS prescription pad requirement goes into effect April 1
Posted March 19, 2008

By Craig Palmer

Washington—As of April 1, 2008, all written prescriptions for Medicaid patients from dentists and other providers must be on tamper-resistant pads. This includes computer-generated prescriptions printed on paper inserted into a printer.

The Association and other professional organizations successfully urged delay of the anti-fraud and abuse requirement that was scheduled to take effect Oct. 1, 2007, to give members time to prepare. When the six-month moratorium expires, all hand-written Medicaid prescriptions must have at least one tamper-resistant feature to prevent copying, erasure or counterfeiting.

Some states require tamper-resistant prescriptions but many don't. The impact will be minimal for dentists in states already requiring tamper-resistant pads, the Association says. Dentists in other states must use new pads from their dental supply firms for all Medicaid prescriptions beginning April 1. Your state dental executive, the state Medicaid directors Web site Link opens in separate window. Pop-up Blocker may need to be disabled. and the Centers for Medicare & Medicaid Services Link opens in separate window. Pop-up Blocker may need to be disabled. are among information sources.

A congressional "Dear Colleague" letter alerting members of the House of Representatives to the April 1 effective date says there is no national standard and that CMS deferred to the states the features they will accept for a prescription to be considered tamper-resistant. The letter cites educational materials at the National Council for Prescription Drug Programs Web site Link opens in separate window. Pop-up Blocker may need to be disabled. (compressed file download), which offers a question and answer format.

Q. Does this requirement pertain to prescriptions received by fax, telephone or electronically?
A. No. Since fax, telephone and electronic prescriptions are sent directly to the pharmacy, they are excluded from the new federal requirements. The direct communication from the prescribing doctor to the pharmacist is considered tamper-resistant.

Q. Does the tamper-resistant requirement apply to over-the-counter (OTC) products?
A. Yes. OTC products that require a prescription for reimbursement under Medicaid must be written on a tamper-resistant prescription paper.

The regulations require use of prescription pads with at least one security feature April 1 and three by Oct. 1, 2008.

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