Pharmacy Facts
MassHealth Pharmacy Program
www.mass.gov/masshealth/pharmacy

Number 44 
September 24, 2008  

• Editor: Vic Vangel 
• Contributors: Chris Burke, Gary Gilmore, Paul Jeffrey, James Monahan, 
  Chuck Young, Nancy Schiff  

Update to the Tamper Resistant 
Prescription Requirement and Computer-
Generated Prescriptions 

This issue provides important information about 
compliance with the Medicaid tamper-resistant 
prescription requirements, and expands upon information 
described in Pharmacy Facts 37 (April 4, 2008) and 
MassHealth All Provider Bulletin 174 (April 2008). 

Prior guidance from the Centers for Medicare and 
Medicaid Services (CMS) on printed prescriptions 
generated from electronic medical records (EMRs) or e-
Prescribing applications stated that special copy-resistant 
paper would likely be required for printed prescriptions to 
be in compliance as of October 1, 2008. CMS has 
clarified this by stating that while special paper may be 
used to achieve copy resistance, it is not required. EMR 
or e-Prescribing-generated prescriptions may be printed 
on plain paper and be fully compliant with all three 
categories of tamper resistance, provided that they 
satisfy at least one feature from each of the three 
categories listed below. CMS has specifically stated that 
the features included in these categories are considered 
tamper resistant for computer-generated prescriptions. 

Category 1: Copy Resistance 

Feature  

A) Void/Illegal/Copy
Pantograph with or
without Reverse Rx 

Description

The word “void,” “illegal,” or “copy” 
appears when the prescription 
is copied. 

Feature

B) Microprint signature
line for prescriptions
generated by an EMR 

Description

Very small font which is legible 
(readable) when viewed at 5x 
magnification or greater, and 
illegible when copied. 


Category 2: Erasure / Modification Resistance 

Feature  

A) An erasure-
revealing background 
for written prescriptions
printed on “toner-lock”
paper for laser-printed
prescriptions, and on
plain bond paper for
inkjet-printed
prescriptions

Description

The background, which consists 
of a solid color or consistent pattern 
printed onto the paper inhibits 
physical erasure of written or 
printed information on a 
prescription form. Toner-lock 
paper is special printer 
paper that makes erasure 
obvious. Toner-lock paper is not 
necessary for inkjet printers. 


Category 2: Erasure / Modification Resistance 

Feature  

B) Quantity check-off
boxes, refill indicator
refills or “NR”), or
border characteristics
(dispense and refill
number bordered by
asterisks and optionally
spelled out) for
prescriptions generated
by an EMR

Border characteristics 
(dispense and refill 
number bordered by 
asterisks AND spelled out)
 

Description

In addition to the written quantity 
on the prescription, quantities are 
are indicated in ranges. 

Quantities and refill number are 
surrounded by special characters 
such as asterisks to prevent 
modification, e.g., QTY **50**. 

 

Category 3: Counterfeit Resistance 

Feature  

Security features
and descriptions
listed on the 
prescription

Description

A complete list of security 
features on the prescription 
paper, which aids pharmacists in 
the identification of features and 
determining compliance 

There are many other features that can be used to 
determine tamper resistance. For a complete list, refer to 
the National Association of Chain Drug Stores (NACDS) 
Web site at 
http://www.nacds.org/userassets/pdfs/gov_affairs/Issues/ 
Tamper_Resist/FinalLtrMedicaidDrtrsTRPP07_17_08.doc 

Please note that some features used in other states 
(serial numbers, encoding techniques such as bar codes 
and state approved vendor IDs) are not used in 
Massachusetts to determine whether a prescription is 
tamper resistant. 

For more information refer to the CMS Fact Sheet for 
Pharmacists at 
http://www.cms.hhs.gov/pharmacy/downloads/update032808.pdf 

 

Please direct any questions or comments (or to be taken off of this fax distribution) 
to Victor Moquin of ACS at 617-423-9830.