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               Phase 1: Center for Medicare and Medicaid Services Guidelines
                              October 1, 2010 – June 30, 2011

     Starting October 1, 2010, all Delaware practitioners must use prescription pads which satisfy
     guidelines issued by the Center for Medicare and Medicaid Services (CMS). The CMS
     guidelines are described below. They apply to all prescriptions in Delaware other than
     prescriptions generated in a licensed medical facility for patients being treated in the facility.

     Starting July 1, 2011, practitioners must switch to State-approved tamper-resistant prescription
     pads purchased from State-approved vendor(s). You will receive information about the features
     of the new pads prior to the July 1st effective date.

Federal law has required practitioners to write Medicaid prescriptions on tamper-resistant pads since
October 1, 2008. In order to be Medicaid-compliant, the pads must have one or more industry-
recognized features designed to prevent each of the following abuses:
   • Unauthorized copying of a completed or blank prescription form
   • Erasure or modification of information that the prescriber wrote on the prescription
   • Use of counterfeit prescription forms

When a prescription is non-compliant, pharmacies must call prescribers for verification. Patients may be
at risk of not receiving their medication when verification is not received.

To assist in evaluating a prescription, pharmacists should use the following checklist.

   The prescription blank should describe the security features on the front or back of the document.

   Prescriptions, other than those generated by EMR or E-prescribing, must be printed on security
   • To identify security paper, hold the prescription to a light source to look for a watermark on the
       front or back. If you cannot see a watermark, photocopy the prescription. The copy should
       display a word such as “VOID” or “ILLEGAL” to indicate the original was on security paper.
   • Prescriptions generated by EMR or E-prescribing may be printed on plain paper only if they
       contain other features to prevent unauthorized copying, erasure or modification of information,
       and use of counterfeit forms.

   The blank should have a double check for the quantity ordered. This could mean the quantity is
   specified as numeric (e.g., 10) and has a quantity range check-off box. Normal ranges are 1-24, 25-
   49, 50-74, 75-100, 101-150, 151 and over. Quantities can have both alpha and numeric
   representation (e.g., 10 and “ten”).

    Each blank should have only one medication to prevent the addition of medications after the initial
    prescription is written.

   An area with thermochromic ink (sensitive to heat and changes color) will demonstrate an authentic
   prescription. The specified area will change colors when tightly held between two fingers or rubbed
   quickly. These areas normally are colored and change to white.

   Prescriptions may have a serial number. Pharmacy personnel should review the number and check
   that they are not repetitive.

   There may be duplicate or triplicate blanks. To verify if the original has been altered, the pharmacy
   will call the practice.

   Check the back of the prescription for a pattern break that may indicate it has been cut and taped.

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