You see, I work in an area of my state that has been hit significantly by the current economic downturn and a considerable portion of my patient population has Medicaid. Even before the economy started to tank there was quite a large portion of my patients who were on Medicaid.
So you would think that the local prescribers would maybe know the rules for prescriptions found in section 7002(b) if the U.S. Troop Readiness, Veterans' Care, Katrina Recovery, and Iraq Accountability Appropriations Act of 2007. To you and me this is the tamper-resistant prescription rule.
And still, on a daily basis, I have to call at least once a day to the same handful of prescribers to notify them that the prescriptions that were just brought to me did not meet the standards of:
- one or more features to prevent the unauthorized copying of the prescription
- one of more features to prevent erasing and modification of the prescription
- one of more features to prevent the use of counterfeit prescription forms
Are they really that dense? Or are the members of the office staff afraid to tell Dr God that he/she needs to order new script pads? I suppose that I can cut some slack to the one physician because spent significant time in Iraq working at a military hospital and he usually e-scribes. He tends to miss the patients whose services are paid for my a Medicaid HMO.
But there is no excuse for Dr God, DDS who just plain out refuses to order the right type of prescription pads. Since my state doesn't require reporting of prescribers who fail to use the tamper-resistant prescription pads, Dr God, DDS can continue to think that he is above the law.
If there is an audit by Medicaid and the prescriptions are deemed to not be written on the tamper-resistant paper, it's the pharmacist/pharmacy who pays. Seems fair, doesn't it? Especially when it's 20 minutes before closing and the patient needs their penicillin and ibuprofen. But they don't have their insurance card so they want it billed as cash. Three days later they come back with their insurance card for a re-bill and it's a Medicaid HMO card. Oh yeah, Dr God DDS didn't use the right kind of paper.
Do you re-bill it and hope to not get audited?
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To this pharmacist there are two simple solutions
- e-scripts/faxes for all scripts that fall under the CMS guidelines. You know for darn sure that the prescriber knows who the payor is. Require the scripts be issued this way.
- denial of payment to the prescriber if they issue a prescription that does not meet the CMS guidelines. Hit them in the pocketbook instead of the pharmacist/ pharmacy. What incentive does the prescriber have to spend extra money on tamper-resistant prescription pads if the pharmacist/ pharmacy are the ones being hit with the penalties? My guess is that it would take two billing cycles for the prescriber to get new pads if they are denied payment.
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We like to complain about all of the rules and regulations that have been dumped on us over the last several years. Poor, poor pharmacist. Look at all the non-pharmacist stuff we have to do. I didn't go to school that long to be the Sudafed-cop? I'm as guilty as the next pharmacist when it comes to this. Sadly, when we get the faxes about the proposed rule changes we shrug our shoulders and drop the fax in the trash. What good will it do to call and comment on the proposed rule changes?
Maybe it's time that we quit whining and put on our big-boy pants. When you get that fax or email, make the call. Maybe call two or three times. Take a little bit of personal ownership of your profession. It's easy to whine and complain. As long as we, as a profession, allow others to dictate how our profession is being practiced, things won't change.