If you still haven’t ordered your tamper resistant Rx Pads, you probably should do so this week.
Normal turn times are about a week, plus shipping, so time is running out.
Moreover, many plants are expected to run out of stock during the week before 4/1/08.
PLAN AHEAD!
If history is an indicator, the week before April 1, 2008 will be a busy one for printers, print brokers and paper manufacturers that deal with tamper-resistant prescriptions.
Last September, before the rule was extended, manufacturers were overwhelmed with last minute orders prompting back orders.
For example, typically Doctor Stuff has a turn around of about 5 business days plus shipping time. Starting March 15, we expect to have an 8 day turn time and are trying to put some measures into place to help existing customers meet the compliance date.
The bottom line is to order early to make sure that you have them in time.
From DrugTopics.com, Feb 5, 2008
“With only two months left before Medicaid prescriptions must be written on tamper-resistant Rx pads, the National Council for Prescription Drug Programs (NCPDP) has issued some new resources (see below) pharmacists can use to prepare for this change. The resources include a model letter for prescribers that states may use as a template. The letter reminds prescribers that:
In addition, NCPDP considered all the tamper-resistant features in the three categories and came out with its findings on which features it favors, because they are less costly and easy to implement, and which ones are harder to implement. NCPDP urges prescribers to implement all the security features by April 1, instead of phasing in some by April 1, and then adding new ones by Oct. 1. The latter approach would be wasteful of paper and pads, it explained.”
New Resources mentioned above:
Draft Letter to Prescribers (Word Document)
From CMS:
On Saturday, September 29, 2007, President Bush signed the “Extenders Law,” delaying the implementation date for all paper Medicaid prescriptions to be written on tamper-resistant paper. Under the new law, as of April 1, 2008, all written Medicaid prescriptions must be on tamper-resistant prescription pads.
CMS’ guidance on the tamper-resistant law, set forth in an August 17, 2007 State Medicaid Director letter, contains two phases. For the first, a prescription must contain at least one of the three tamper-resistant characteristics in order to be considered “tamper resistant.” For the second, prescriptions must contain all three characteristics.
The two-phased approach is still in effect. At least one of the three tamper-resistant characteristics is required on April 1, 2008. All three characteristics are required on October 1, 2008.
In response to strong concerns from physicians, pharmacists, and others, Congress delayed the regulation mandating the use of tamper-proof prescriptions for Medicaid patients for six months. If President Bush signs the legislation as expected, the new deadline is March 1, 2008.
Physicians and pharmacists contended that they weren’t given enough time to obtain the new prescription pads, and manufacturers said they were getting so many orders that they could not keep up with the demand.
It seems that providers are realizing that they need to be prepared by next week. But it seems that they may have problems complying.
Because of the demand, several of the largest manufacturers of tamper-resistant security paper for prescriptions are out of stock.
These manufacturers supply local, regional and national printers with this paper and the back order will cause delays for many to implement.
When I called to order some blank stock for some of my customers, Paris Business Forms, for example, told me that they were on a 2-3 week backorder. They have dedicated extra shifts to the problem, but they can’t satisfy the demand.
From the National Association of State Medicaid Directors
A quick review of the CMS guideline to State Medicaid Directors:
The tamper-resistant pad requirement does not apply to refills of written prescriptions presented at a pharmacy before October 1, 2007. In addition, the payment limitation does not apply when:
It does not restrict emergency fills of non-controlled or controlled dangerous substances for which a prescriber provides the pharmacy with a verbal, faxed, electronic, or compliant written prescription within 72 hours after the date on which the prescription was filled.