Regarding CMS to allow alternatives to tamper-proof paper: As the speaker referenced in the item, I am delighted that the collaboration of many stakeholders, led by the National Council for Prescription Drug Programs, or NCPDP, was able to make compliance with the Medicaid Tamper Resistant Prescription Pad Law more reasonable and more effective for electronic health-record users, who occasionally still have to print Medicaid prescriptions. As I made very clear during my talk at the meeting of the Association of Medical Directors of Information Systems, I could discuss the process and direction that our collaboration was taking, but that public notification of that clarified guidance would come from the CMS and NCPDPand not from my comments.
More importantly, while my colleagues might view an outcome that allows compliance with the tamper-resistant law to be achieved with printer security solutions and not solely with tamper-resistant paper as overturning the CMS regulationsthis is a mischaracterization of our work and the collaboration that achieved it.
The Physicians Electronic Health Record Coalition and the Electronic Health Record Vendors Association strongly support efforts that decrease the potential for prescription fraud. We simply believed that the law and the first set of regulations surrounding the law needed more clarityparticularly when applied to printed prescriptions from EHRs or e-prescribing applications.
Peter Basch, M.D.Medical directorAmbulatory clinical systemsMedStar HealthColumbia, Md.