OLYMPIA -- Under federal law, all written Medicaid fee-for-service prescriptions must be written on tamper-resistant prescription pads, beginning Tuesday, April 1, 2008. In all, about half of the 900,000 Washington State Medicaid clients may be affected by the new rule.

The requirement, passed in 2007 and originally scheduled to have taken effect last fall, applies only to written prescriptions, not those telephoned, faxed or e-mailed electronically to a pharmacy.

It also does not apply to:

• Medicaid prescriptions issued by providers in Healthy Options or other medical assistance managed care plans and which are reimbursed through the managed care plan.
• Medications dispensed and are part of the per diem rate in designated institutional or clinical settings.
• Prescription refills when the original prescription was written before the April 1, 2008, deadline.

Prescribers and pharmacists can access additional information on the new law on the Washington State Medicaid Web page ( http://maa.dshs.wa.gov ) or on the federal Medicaid Web site at http://www.cms.hhs.gov/center/intergovernmental.asp DSHS also is distributing notices about the change to pharmacies and providers this week.

Pharmacists also are allowed to use emergency dispensing procedures in Washington State. In those circumstances, the pharmacy may fill the prescription as long as the pharmacy later verifies it with the prescriber and a faxed, electronic, or compliant written prescription from the prescriber is forwarded to the pharmacy within 72 hours after the prescription was filled.

A list of vendors offering tamper-resistant paper is posted on the Washington State Web site. Pharmacies and providers should obtain a document certifying any vendor's claim that its product meets the federal specifications.

Under federal regulations, the tamper-resistant prescription forms in use on April 1 must meet at least one of the following characteristics:

• No copying: Pads must prevent unauthorized copying of completed or blank prescription forms. For example: Pantographs that reveal the word "void" when copied.
• No alterations: Pads must prevent erasure or modification of writing on the prescription form. For example, chemical stains or altered background reveal attempts at ink or toner removal.
• No counterfeiting: Pads must be distinctive and can't be reproduced, such as a watermark.

After October 1, 2008, the federal guidelines say the paper must meet all three characteristics to be considered tamper-resistant.

The Department of Social and Health Services (DSHS) is encouraging Washington Medicaid pharmacists to verify prescriptions on noncompliant pads by calling, faxing, or e-mailing prescribers whenever possible to ensure continuity of care and access to necessary medications for Medicaid recipients.

However, all providers are cautioned to be rigorous about the possibility of tampered prescriptions in the case of Schedule II drugs and to report any suspicious prescriptions to the prescribing provider as quickly as possible.

FOR MORE INFORMATION AND BACKGROUND: Jim Stevenson, Communications Director, HRSA, DSHS, 360-902-7604 (Pager: 360-971-4067).