***Tamper-Resistant
Prescription Pads POSTPONED
until March 31, 2008***
Tamper-Resistant Prescription Pads
Beginning April 1, 2008, Montana Medicaid will require WRITTEN Medicaid prescriptions to be written on Tamper-Resistant Prescription Pads that meet the following criteria:
- 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, or
- One or more industry-recognized features designed to prevent the use of counterfeit prescription forms.
Beginning October 1, 2008, the Tamper-Resistant Prescription Pads must contain all 3 characteristics as mandated by CMS.
In addition, also beginning April 1, 2008, Medicaid and MHSP claims will require a “Prescription Origin Code”: (click here to read full notice)
- 0—not specified
- 1—written prescription
- 2—telephoned prescription
- 3—electronic prescription
- 4—facsimile prescription
Pharmacies may fill the full prescription of covered outpatient drugs written on non-compliant prescription pads, or a portion thereof at the pharmacist’s discretion. However, pharmacies must verbally confirm the non-compliant prescription and document the call on the face of the prescription, or obtain a faxed, electronic, or compliant written prescription within 72 hours of the date the prescription was filled.
*Most systems have this “origin code” feature easily accessible when you ENTER A NEW PRESCRIPTION, including QS1 systems and McKesson systems.
You may visit www.MTPharmacist.org ( In the Spotlight) or www.mtmedicaid.org for more information. In addition, you may find a link on either site for a list of CMS approved pad vendors (including 1 in Great Falls, and 1 in Helena).
**For claims questions or additional information, contact Wendy Blackwood, Pharmacy Program Officer, at (406) 444-2738
*see below for full notice*
Montana
Medicaid Notice
Physicians, Mid-Level Providers, Dentists,
Pharmacies, and Inpatient and Outpatient Hospitals
Tamper-Resistant Prescription Pads — UPDATED
The Centers for Medicare and Medicaid Services
(CMS) released guidance to state Medicaid programs
regarding a new law requiring the use of Tamper-Resistant
Prescription Pads. Beginning October 1, 2007,
all written Medicaid prescriptions must be on
Tamper-Resistant prescription pads. This requirement
applies to all outpatient drugs, including over-the-counter
medications, regardless of whether Medicaid is
the primary or secondary payor. Prescriptions
may still be telephoned, faxed, or transmitted
electronically (e-prescribed) to pharmacies as
allowed by current federal and state regulations.
Initial Department guidance issued September
7th proposed the use of indelible ink in an alphanumeric
format. Though the Department determined this
met the intent of the law, CMS issued an additional
Frequently Asked Questions (FAQ) document which
stated this practice was not acceptable.
CMS provided further guidance that written orders
prepared in an institutional setting where the
patient never has the opportunity to handle the
written orders are considered “tamper resistant.” The
CMS guidance and FAQ documents are posted at the
Department’s web-site: http://medicaidprovider.hhs.mt.gov/pdf/trpfaqs.pdf
The Tamper Resistant Pad requirement does not
apply to drugs which are “bundled” or
not separately reimbursed in conjunction with
services provided in nursing facilities, intermediate
care facilities, and other specified institutional
and clinical settings as described by 42 USC 1927
(k)(3) http://www.ssa.gov/OP_Home/ssact/title19/1927.html.
This requirement does not apply to refills of prescriptions written before
October 1, 2007.
Requirements and Guidance
Montana Medicaid encourages prescribers to telephone, fax or electronically
transmit prescriptions to pharmacies.
Beginning October 1, 2007, CMS will require that a Medicaid prescription
pad shall contain one of the following three characteristics:
1. One or more industry-recognized features designed
to prevent unauthorized copying of a completed
or blank prescription form;
2. One or more industry-recognized features designed to prevent the erasure
or modification of information written on the prescription by the prescriber,
and
3. One or more industry-recognized features designed to prevent the use
of counterfeit prescription forms.
Beginning October 1, 2008, a written Medicaid
prescription must contain all three characteristics.
Pharmacies may fill the full prescription of
covered outpatient drugs written on non-compliant
prescription pads, or a portion thereof at the
pharmacist’s discretion. However, pharmacies
must verbally confirm the non-compliant prescription
and document the call on the face of the prescription,
or obtain a faxed, electronic, or compliant written
prescription within 72 hours of the date the prescription
was filled.
The Department is compiling a list of vendors
which can produce compliant pads. This list shall
be posted on the DPHHS web page and updated regularly
as new vendors are identified. This list is not
exclusive and prescribers may contact the Department
to confirm the acceptability of their tamper resistant
pad.
Schedule II (CII) Drugs
Schedule II prescriptions must be in writing to comply with DEA and Montana
Board of Pharmacy regulations specified in ARM 24.174.523. While pharmacies
cannot fill faxed or verbal CII prescriptions, prescribers can use these
methods to provide confirmation to pharmacies. In accordance with CMS
guidance, faxed or verbal confirmation will render the CII prescription,
written on non-tamper resistant paper, compliant.
Enforcement
Currently, the Federal law and CMS guidelines apply only to Medicaid clients’ prescriptions.
It will be essential to identify any Medicaid eligibility at the time the
prescriptions are written and/ or filled to ensure that those prescriptions
comply with the applicable rules. CMS requires the States to enforce the
tamper resistant pad requirement. The Department is developing audit procedures
to ensure compliance.
Verifying Client Eligibility
There are several eligibility verification methods available using the
client member number/card control number printing on the Montana Access
to Health Card.
• Web Portal: https://mtaccesstohealth.acs-shc.com/mt/general/home.do
will provide
online eligibility information. Registration as a provider is necessary.
• FAXBACK 800-714-0075: Returns a copy of the client’s eligibility
when given the client’s identification number, via fax to the provider
within a couple of minutes after ending the call. Please make sure your fax number
is on record with ACS to use this free service.
• AVRS (Automated Voice Response System) 800-714-0060: Provides the client’s
eligibility
and billable identification number through an automated voice system.
• Provider Relations Department 800-624-3958 (in-state) 406-442-1837 (Helena
and outof- state): Verify eligibility with Provider Relations Monday-Friday from
8 am to 5 pm.
Please direct any questions regarding this notice to the following personnel:
Physician and Mid-Level providers: Denise Brunett at (406) 444-5778; Dentists:
Jan Paulsen at (406) 444-3182;
Pharmacy providers: Wendy Blackwood at (406) 444-2738; Hospitals: Debra
Stipcich at (406) 444-4834.
Contact Information
For claims questions or additional information, contact Provider Relations:
Provider Relations toll-free in- and out-of-state: 1-800-624-3958
Helena: (406) 442-1837
Visit the Provider Information website:
http://www.mtmedicaid.org/
|
