This is a common question I get when doing records management training. It is often accompanied by the inevitable… can I use an e-mail for a prescription? Once again, the answer is on our helpful DEA guide at https://www.deadiversion.usdoj.gov/pubs/manuals/pract/pract_manual012508.pdf. The answer is that the DEA *recommends* “7. Use tamper-resistant prescription pads. ”
But what does “tamper resistant” mean? Good news, CMS (“the Centers for Medicare & Medicaid Services”) has issued guidance to the States on what in the world a tamper-resistant pad is…. a prescription pad must contain:
- One or more industry-recognized features designed to prevent unauthorized copying of a completed or blank prescription form;
- One or more industry-recognized features designed to prevent the erasure or modification of information written on the prescription by the prescriber; or,
- One or more industry-recognized features designed to prevent the use of counterfeit prescription forms.
Now the CMS does not govern veterinary medicine, but I’d rely on the DEA treating this as analogous, since they use the same term and govern both human and veterinary prescriptions of controlled substances.
There’s no particular brand or type required, but you should focus on the ability through fraud, theft, or collusion to create an unauthorized prescription in your name or with your number. Just because a vendor or on-line site says their prescription pad is “tamper-resistant”, I wouldn’t trust them. I read the description and determine if the above three criteria are met.
Also, a computer generated prescription, on tamper proof prescription paper, may meet the requirements above. Don’t just use the paper you get from staples if you are taking this route, and even if you do, you still have to sign it.
Also, make sure the pad has room for the following information, as specified in the manual on page 30.
“Each prescription must indicate the full name and address of the patient, the drug name, strength, dosage form, quantity prescribed, directions for use and the name, address, and DEA number of the practitioner.”
It should have a place for signature, as well as the date of the signature.
Lastly, we have to remember to get it right, since you shouldn’t be able to erase or modify. I think it’s best to destroy the prescription, make a record of it, and then create a new one if you make a mistake when writing it.
So, until the next time, let’s get better together!