MINNEAPOLIS, March 20—In 2007, Congress enacted a law requiring that, in order to be eligible for federal reimbursement to Medicaid, all Medicaid prescriptions had to be written on “tamper-resistant” pads or paper.

While this is a federal law, there is not a single national regulation. Each state Medicaid agency must implement its own requirements regarding which tamper-resistant features will be required in that state.

MHCP has reviewed the recommendations of industry and of states that currently use tamper-resistant prescription pads/paper. MHCP has chosen to allow providers to select any one security characteristic per category.

The acceptable characteristics are outlined in the NCPDP letter to Medicaid. We recommend that providers identify the tamper-resistant features on the blank to allow pharmacists to identify and check for tampering.

CMS has set two deadlines for this requirement:

• Beginning April 1, 2008, all prescription pads/paper for prescriptions written for Medicaid fee-for-service recipients/members are required to have at least one of the tamper-resistant characteristics from one of the tamper-resistant categories. Prescriptions generated by an automated medical record, that print a unique number on each prescription, would satisfy this requirement.
• Beginning October 1, 2008, prescription pads/paper will be required to have at least one of the tamper-resistant characteristics from all three tamper-resistant categories. At this point, prescriptions generated by an automated medical record, that prints a unique number on each prescription, would not satisfy the requirement of meeting all three categories.

CMS encourages providers to implement all security features by April 1, 2008, to avoid wasting old pads and paper and reordering and using new pads and paper with the additional features before October 1, 2008.

Providers who write prescriptions for MHCP recipients should contact their printer to secure an appropriate supply of tamper-resistant prescription pads or paper that will meet CMS April 1, 2008, requirements and begin using this paper before April 1, 2008. Orders may take up to four weeks to process.

If you or your printer/vendor require additional information, please refer to the NCPDP letter to Medicaid. This document provides an example of a tamper-resistant prescription pad/paper, a description of the required security features, a listing of tamper-resistant prescription pad/paper vendors and a summary of the Federal law and Medicaid requirements.