Denti-Cal Rx requirement delayed

New deadline for Tamper-resistant prescription pad requirement for Denti-Cal Providers

According to a new federal Medicaid requirement, providers in California’s Denti-Cal program were to begin using tamper-resistant pads for all written prescriptions beginning October 1, 2007.  However, the October compliance date proved impossible to meet and has been delayed 6 months.  The new effective date for this requirement is April 1, 2008.

Q: What exactly does this requirement mean for California’s Denti-Cal providers?
A: The prescription pad California already requires for controlled substances meets the tamper-resistance requirements of the new law.  To simplify this for your office, if you currently use a prescription pad for controlled substances, use this pad for all written prescriptions for your Denti-Cal patients. If you do not currently prescribe controlled substances, information on how to order tamper-resistant pads is provided below.

Also, remember that this requirement only applies to written prescriptions, it does not apply to:

• prescriptions transmitted electronically to the pharmacy;
• prescriptions faxed to the pharmacy;
• prescriptions communicated to the pharmacy by telephone by a prescriber;
• the transfer of a prescription between two pharmacies, provided that the receiving pharmacy is able to confirm by facsimile or phone call the authenticity of the tamper-resistant prescription with the original pharmacy;
• written orders prepared in an institutional setting (which include Intermediate Care Facilities and Nursing Facilities), provided that the beneficiary never has the opportunity to handle the written order and the order is given by medical staff directly to the dispensing pharmacy;
• drugs dispensed or administered directly to the beneficiary from or in the physician’s office or clinic;
• emergency fills, provided that the prescriber provides a verbal, faxed, electronic, or compliant written prescription within 72 hours;
• prescriptions paid for by Medi-Cal managed care organizations, provided that the drug is not carved out of managed care.  Written prescriptions for drugs carved out of managed care must be executed on a tamper-resistant pad.

Q:  What makes a prescription pad tamper-resistant?
A:  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.

Q: Where do I get the required prescription pads?
A: The California-required tamper-resistant prescription pads for controlled drugs fully meet this new requirement now. Therefore, prescribers are encouraged to use the current pads in order to fulfill the new federal law, and may order tamper-resistant prescription pads from security prescription printer companies that have been pre-approved to produce the forms by the California Department of Justice and Board of Pharmacy.  The directory of approved companies can be found at www.ag.ca.gov/bne/security_printer_list.php.  This directory provides an alphabetical listing of companies and is updated as new security prescription printers are approved.  Your prescriber’s state license number and a copy of your DEA Registration are needed when you place the order. 

To learn more about this law, visit the Center for Medicaid and Medicare website at: www.cms.hhs.gov/DeficitReductionAct/Downloads/MIPTRPFAQs9122007.pdf