The Pharmacist's Information Resource www.RxSecurityFeatures.com
The Pharmacist's Information Resource
for validating Prescription Paper Security Features
Dedicated to the Prevention of Unauthorized Script Duplication and Modification
FAQ ~ Frequently Asked Questions


Q
All Medicaid Scripts must be on Tamper Resistant Paper.
How do you define Tamper Resistant as it relates to this law ?
A
To be considered tamper resistant,
a prescription must contain at least one tamper resistant security feature in each 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;

3) one or more industry-recognized features designed to prevent the use of counterfeit prescription forms.


CLAIRIFICATION PROVIDED BY CMS
(Centers for Medicare and Medicaid Services)

Several States have had questions about whether a provider can add a feature to a prescription to make it compliant with requirements. States have proposed various features including particular kinds of ink to write the prescription (gel or indelible), writing out the drug quantities rather than just the number (i.e. "thirty" vs "30") and embossed logos.

The statue states that all written prescriptions must be "executed on a tamper resistant pad" (paper). As a result, features added to the prescription after they are printed (written) do not meet the requirement of the statute. Features that would make the prescription tamper-resistant include certain types of paper as well as certain items that can be pre-printed on the paper.


Q
I made a copy on my photocopier and the hidden message did not appear.
A
Most Document Security Papers incorporate "Hidden Message Technology." There are a number of patented methods used to accomplish this task. However due to changing copier technology, you may find that your document can be duplicated on some photo copiers without the words "VOID" "COPY" or other hidden messages showing up on the copy. For this reason we advise purchasing document security paper that incorporates more than one security feature.
Remember, the reason document security paper is used is to "prevent accurate document duplication." A document printed on Security Paper that contains numerous security features, features such as "color change ink" for example, is virtually impossible to accurately duplicate using a standard or color copier, scanner or even a digital camera.
Security Paper is used to help prevent the unauthorized duplication of any document.
To secure a document, it is very important to use multiple security features.
A document that contains only one feature, a VOID background for example, may be duplicated on some photo copiers without the word VOID showing up on the copy.

The reason the United States Government does not include hidden message technology in US currency is because it does not work 100% of the time.

Q
Explain how the Erasure Protection Feature works.
I tried to erase the background with my eraser and did not remove any of the background color.
A
When a doctor writes a prescription, it is written using an ink or ball point pen, not a pencil. When trying to remove information written on a prescription using an ink eraser, a small amount of the background color is removed with the ink. Thus it becomes obvious that a change was made to the script.

Q
Secure Rub "Color Change Ink" is listed on the Security Feature List.
However I do not see this feature on either the front or back of the script.
A
"Color Change Ink" may be difficult to see ...especially during hot weather.
During hot weather or if the script has been in a hot location, the heat may have caused the color to change.
To verify this feature, place script in the refrigerator for 30 seconds.
This will cause the color to return to it's original state.

Q
You say that there are numerous security features available to prevent accurate document duplication.
Can you describe some of these features ?
A
There are features such as "unit "check boxes".
  • These boxes act as a "check and balance" to insure the patient receives the prescribed dosage.

  • Features such as paper "Chemical Reactivity." This feature causes paper to react to different chemicals.
  • In addition to the added expense for the paper, the pharmacist may find this feature inconvenient to validate.

  • Security Holograms are impossible to duplicate, but are an expensive feature.

  • Q
    Is there a list of states that require "special" Security Paper for printing prescriptions?
    A
    Yes.
  • California
  • Delaware
  • Florida
  • Georgia
  • Indiana
  • Kentucky
  • Maine
  • New Jersey
  • Washington
  • West Virginia (optional)
  • Wyoming

    Note, while other states do not require special security paper features, they may require that a "Special Format" is printed on Medical Prescription.
    These states include:
    Louisiana, Massachusetts, Mississippi, Pennsylvania, Texas


  • Q
    How do I order prescription paper for use in the State of New York?
    A
    Effective April 19, 2006, all prescriptions (both for controlled substances AND non-controlled substances)
    written in New York State must be issued on an official New York State Prescription form.

    All practitioners must obtain prescription forms from the New York Department of Health.
    There are NO approved prescription paper printers in the State of New York.

    Under the new law, New York pharmacies are required to submit data to the New York State Department of Health.
    They are required to submit specific information from prescriptions dispensed for all controlled substances.
    The New York Department of Health will monitor this data.


    Q
    I practice in the State of New Jersey. I have just moved to a new office and need to order new prescription pads.
    A
    You need to submit your address change to the State of New Jersey.
    The State of New Jersey requires that the address to which your prescription pads are shipped MUST be the address on file with the State.
    Before you order new Rx pads, be sure you have made the address change with the State of New Jersey.

    Q
    The States of California, Indiana, Kentucky, Maine, New Jersey, and New York have prescription paper regulations. Will a second set of prescriptions be required to meet the 2008 Medicaid Law?
    A
    The following is an excerpt from the August 2007 letter sent to all State Medicaid Directors; "States are free to exceed the above baseline standard as to what constitutes a tamper-resistant prescription pad. States should make their own determination whether to allow pharmacists to accept an out-of-State prescription that meets the tamper-resistant requirements of another State.
    Several States have laws and regulations concerning mandatory, tamper-resistant prescription pad programs, which were in effect prior to the passage of section 7002(b). CMS deems that the tamper-resistant prescription pad characteristics required by these States' laws and regulations meet or exceed the baseline standard, as set forth above."

    Q
    Can the Federal Government pass a law requiring that
    all medical prescriptions must be on secure paper?
    A
    Medicaid is a Government Program.
    Thus the Government has the right to determine the rules for this program. Requiring that Medicaid Prescriptions must be on Tamper Resistant Paper falls under the regulations for participation in the Medicaid Program.

    However when it comes to the method used to prescribe medications,
    State licensure systems that grant physicians the exclusive right to prescribe and pharmacists the exclusive right to dispense prescription medication are protected under Article Ten of the United States Constitution.

    Historically, under Article X of the U.S. Constitution, states have the authority to regulate activities that affect the health, safety and welfare of their citizens. In 1889, state licensure systems that granted physicians the exclusive right to prescribe and pharmacists the exclusive right to dispence prescription medication were tested and found valid. In Dent v West Virginia, 129 U.S. 114 (1889), the Supreme Court denied a due process challenge to a West Virginia medical practice act that required state licensure of physicians.

    Thus any regulations as they relate to how physicians prescribe and how pharmacists dispense prescription medication are the responsibility of the States.



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