Archive for August, 2007
State Medicaid Director Letter (SMD)
Monday, August 20th, 2007Review of Tamper-Resistant Security Guidelines – Exemptions
Sunday, August 19th, 2007A 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:
- e-prescriptions are transmitted to the pharmacy
- prescriptions are faxed to the pharmacy
- prescriptions are communicated to the pharmacy by telephone by a prescriber.
- when a managed care entity pays for the prescription.
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.
Tamper Resistant Prescription Paper Requirements
Saturday, August 18th, 2007Further guidelines on what is “tamper-resistant”:
There are two time tables in place, with the first deadline fast-approaching.
To be considered tamper resistant on October 1, 2007, a prescription pad must contain at least one of the following three characteristics:
- one or more industry-recognized features designed to prevent unauthorized copying of a completed or blank prescription form;
- one or more industry-recognized features designed to prevent the erasure or modification of information written on the prescription by the prescriber;
- one or more industry-recognized features designed to prevent the use of counterfeit prescription forms.
In order to be considered tamper-resistant after October 1, 2008, a prescription pad must contain all of the above three characteristics.
States are free to exceed the above baseline standard as to what constitutes a tamper-resistant prescription pad.
All of the states that currently have laws and regulations concerning mandatory, tamper-resistant prescription pad programs, which were in effect prior to the passage of section 7002(b) meet or exceed the baseline standard, so no changes are required in those states.
CMS Issues Guidance on Medicaid Prescription Requirement
Friday, August 17th, 2007CMS issued a guidance to State Medicaid Directors.
http://www.cms.hhs.gov/SMDL/downloads/SMD081707.pdf