What is tamper-resistant prescription paper or pads?

Tamper-resistant prescription paper or pad means a prescription pad or paper that has been approved by the Board of Pharmacy for use in Washington and contains one or more industry-recognized feature to prevent each of the following:

• Unauthorized copying of a completed or blank prescription form.
• Erasure or modification of information written on the prescription by the prescriber.
• Use of counterfeit prescription forms.

What are industry-recognized features?

Examples of industry-recognized features include:

• The word “Void,” “Illegal,” or “Copy” appearing when the prescription is photocopied or faxed.
• A background consisting of a solid color or pattern that is printed on the paper. This stops a forger from physically erasing written or printed information on a prescription form.
• A complete list of the security features on the prescription paper. This aids pharmacists in identifying features and determining compliance.

Is the Washington State law different than the federal Medicaid Tamper-Resistant Prescription Requirements?

Yes, the new law is different from the federal requirements, however, the Washington State law meets the Medicaid tamper resistant prescription requirement.

* The new law applies to prescriptions written for medication for delivery/dispensing by a pharmacist/pharmacy. It does not apply to prescriptions such as those written for corrective lenses, custom orthotics/prosthetics, etc.

Who must comply?

All practitioners with prescriptive and dispensing authority must comply with this law, including prescriptions written by veterinarians.

Note: The law is intended to increase patient safety and stop people from stealing or altering existing prescriptions. Prescriber has a responsibility to safeguard all prescription pads and paper from theft.

How must they comply?

Beginning July 1, 2010, all prescriptions must be written on tamper-resistant paper approved by the Board of Pharmacy.

There are exceptions included in the law when tamper-resistant prescription paper is not required. RCW 18.64.500.

Are there exceptions in the law when tamper-resistant prescription paper or pads are not required?

Yes. Tamper-resistant prescription paper or pads are not required when:

• Prescriptions are transmitted to the pharmacy electronically, by telephone or by facsimile.
  • CII controlled substance prescriptions must follow federal law and must be handwritten and signed using tamper resistant prescription paper.
• Prescriptions are written for patients in hospitals (whether in patient or as out-patients, residents of nursing homes, or inpatient or residents of a mental health or correctional facilities, if the prescriber writes the order into the patient’s medical or clinical record, the order or prescription is given directly to the pharmacist, and the patient never has the opportunity to handle the written order or prescription.

If at any time the patient or patient’s designee handles the written order or prescription, the prescription must be on approved tamper-resistant paper or pad.

Note: Other federal or state restrictions/limitation may apply for controlled substance prescription see RCW 69.50.308 and 21 CFR 1306.11 (e) & (f).

Does the July 1, 2010 date refer to the date the prescription is filled or written?

The effective date refers to the date the prescription is written. Prescriptions written before July 1, 2010 and are not required to be on tamper-resistant prescription paper unless it is written for a Medicaid recipient.

Can the prescriber add features to the prescription to make it compliant with the requirements such as writing out the drug quantities rather than just the number; using indelible or gel ink; or using an embossed logo?

No. The law requires all written prescriptions to be on tamper-resistant paper or pads (TRPP) approved by the board. Features added to the prescription after it is printed such as a stamp, sticker or indelible ink do not meet the requirements of the law. All board-approved TRPP will have the Board of Pharmacy “seal of approval.”

Will prescriptions printed from a computer need to be on board approved tamper-resistant prescription paper or pads?

If a hard copy of an electronic prescription is printed and given to the patient or patient’s designee, the manually-signed hard copy prescription must be on board approved tamper-resistant paper.

The law does not require prescriptions transmitted to the pharmacy electronically, by telephone or by facsimile to be on board-approved tamper-resistant paper or pad.

Prescribers should never use tamper-resistant prescription paper or pads when faxing a prescription directly to a pharmacy. This will activate the pantograph, which may indicate that the faxed prescription is “Void”, “Invalid” or “Copy

Note: Other federal or state restrictions/limitation may apply for controlled substance prescription see RCW 69.50.308 and 21 CFR 1306.11 (e) & (f).

Are tamper-resistant prescription pads or paper required when over-the-counter products are prescribed?

Yes. Over-the-counter products written as prescriptions must comply with the tamper-resistant requirements.

What is the process for seeking board-approval of tamper-resistant paper or pads?

The Board of Pharmacy has developed a review/approval process for vendors seeking approval of their TRPP.

Tamper-Resistant Rx Review/Approval Process

Are nursing home prescriptions required to be written on board approved tamper resistant paper?

Written orders prepared in an institutional setting where the prescriber (or other designated healthcare practitioner) writes the order into the medical record and then the order is given by medical staff directly to the pharmacy is considered “tamper resistant,” so long as the patient never has the opportunity to handles the written order.

What does Board of Pharmacy approved tamper resistant prescription paper or pads look like?

• The seal of approval appears in the bottom right corner of the prescription form. The seal identifies that the Board of Pharmacy has determined that the paper meets the security features required by law.
• The seal consists of a mortar and pestle watermark with the Washington State map centered over the top. The state is green thermo chromic ink that changes from green to yellow when exposed to heat or friction and back to green when cooled.
• See sample prescription form w/seal.

Where can a prescriber purchase/acquire board approved tamper resistant prescription paper or pads?

Approved paper is widely available. Check with your current paper or prescription supplier to see if they can provide board approved tamper-resistant prescription paper or pads. The Board of Pharmacy does not endorse, credential, or otherwise certify the companies. The board simply reviews and approves tamper resistant paper and authorizes the application of the board's seal to the approval. For more information, please contact the board at wsbop@doh.wa.gov.

Can a prescriber purchase/acquire blank stock of board approved tamper resistant prescription paper or pads for printing in the office using an electronic medical records system or other means?

Yes, the law does not prohibit this practice. It is a business decision for a vendor to provide legitimate requestors with blank stock of the board-approved tamper resistant paper (with the seal affixed) to print prescription/prescriber specific information in the office. You may need to work with the vendor for formatting to ensure that the seal and two signature lines will print appropriately on the form. See sample prescription form w/seal and two signature lines.

Washington state law requires written prescriptions to have two signature lines at the bottom of every form. Under the signature line to the right side of the form “DISPENSE AS WRITTEN” must clearly be printed. Under the signature line on the left side the words “SUBSTITUTION PERMITTED” must clearly be printed. (RCW 69.41.120)

At this time, there are no regulations on the size or layout of a prescription form with except to the seal and the two signature lines. See the sample prescription form w/seal for information on what should be included on a prescription form.

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