Pharmacies continue to reject prescriptions due to noncompliant forms

Verify that your secure Rx forms are compliant

CDA continues to receive calls from dentists who report that pharmacies are rejecting the controlled substances prescriptions they write for patients.

Prescriptions that are out of date or are missing required elements are being rejected by pharmacies, as CDA first reported last November. To date, the vast majority of the rejected prescriptions have been for controlled substances or schedule II-V drugs. These prescriptions must be written on tamper-resistant forms produced by security-prescription printer companies licensed and approved by the California Department of Justice.

But a recent DOJ audit of the licensed security printers identified four printers that continue to print noncompliant forms. The California Board of Pharmacy’s Enforcement and Compounding Committee heard public comment in a December 2017 meeting in which several recommendations were made. Among them was a request for a standardized prescription template to ensure consistent compliance. The committee agreed to “work with the Department of Justice to ensure that prescribers are receiving compliant forms.”

Until a standardized template is introduced, dentists should immediately check that their tamper-resistant prescription forms have the following preprinted elements:

  • A latent, repetitive “void” pattern printed across the entire front of the prescription blank
  • A watermark showing “California Security Prescription” printed on the back
  • A chemical void protection that prevents alteration by chemical washing
  • A feature printed in thermochromic (color-changing) ink
  • An area of opaque writing so that the writing disappears if the prescription is lightened
  • A description of the security features included on each prescription form
  • Six quantity check-off boxes for the prescriber to indicate the quantity by checking the applicable box where the following quantities shall appear:
    1–24 50–74 101–150
    25–49 75–100 151 and over
  • In conjunction with the quantity boxes, a space or line to designate the units referenced in the quantity boxes when the drug is not in tablet or capsule form
  • Printed at the bottom, the statement “Prescription is void if the number of drugs prescribed is not noted.”
  • The preprinted name, category of licensure, license number, federal controlled substance registration number (DEA number) and address of the prescribing practitioner
  • A check box for the prescriber to indicate the number of refills ordered
  • A place to indicate the prescription’s date of origin
  • A check box indicating the prescriber’s order not to substitute
  • An identifying number assigned to the approved security printer by the Department of Justice
  • A check box by the name of each prescriber when a prescription form lists multiple prescribers

Each batch of controlled substance prescription forms will have the lot number printed on the form, and each form within that batch should be numbered sequentially beginning with the numeral 1.

“Learn the required elements on these prescription forms,” advises Teresa Pichay, CDA’s regulatory compliance analyst. “This is the first step to ensuring your patients are not refused prescribed medication at the pharmacy.”

Pichay adds that as not all printers are DOJ-approved, they do not necessarily know what the law requires. And as the pharmacy committee noted in its December meeting, even a few of the approved printers are printing noncompliant forms. The committee noted two major required elements that are frequently missing: the checkoff box to indicate the number of refills and the watermark. Pichay has told dental offices that have the information from their most recent prescription order form to discuss the forms with their printer. She also advises that the noncompliant tamper-resistant forms can still be used for non-narcotic prescriptions such as antibiotics.

The law that establishes the requirements for tamper-resistant forms was last amended in 2012. For descriptions of other requirements for controlled substances prescriptions, read the CDA Practice Support article “Controlled Substances Prescribing and Dispensing.”

A list of state-approved printers can be found on the website of the state attorney general.

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Dentists have reported to CDA that pharmacies have rejected their prescriptions due either to forms that are out of date or are missing required elements. All prescriptions have been for controlled substances, which must be on tamper-resistant forms printed by California-approved printers and containing California-specific pre-printed elements.

CVS Health launched a new initiative in September to help fight the national opioid abuse epidemic by enhancing opioid utilization management, providing drug disposal kiosks nationwide and aiding local communities in treatment and recovery services. The president and CEO of CVS Health said in a news release that addressing the nation’s opioid crisis calls for a multipronged effort involving many health care stakeholders, including dentists.