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Dome - Prescription for compliance

Dome June 2012

Prescription for compliance

Date: June 15, 2012

Hopkins providers are facing a July 1 deadline for complying with federal guidelines to use tamper-proof prescriptions pads, or else they and the enterprise’s individual hospital pharmacies and provider groups could be looking at government fines.

A cross-institutional group working on the issue has set the week of June 18 for providers to swap out old pads for compliant ones, says Mary Myers, vice president and COO of Johns Hopkins Home Care Group, who co-directs a work group handling the issue. Providers can get instructions on exchanging their old pads for new ones by calling a special hotline, 410-288-8998, or emailing

The work group also will be issuing standardized operating procedures for ordering approved prescription pads, along with instructions on how to comply with them, Myers adds. Directions for ordering them are available at

Ironically, many Hopkins providers thought they had been using tamper-proof pads for the past two years, until a government audit proved otherwise. 

In 2007, Congress enacted legislation requiring that all state Medicaid providers dispensing hand-written or computer-generated prescriptions use tamper-resistant paper forms to prevent prescriptions from being photocopied, forged or altered by Medicaid patients or others.

The Maryland Department of Health and Mental Hygiene (DHMH), which administers Medicaid in the state, set a deadline of October 1, 2008, to adopt compliant pads. That same year, The Johns Hopkins Hospital arranged with Standard Register, the printer that provides its prescription pads, to change its templates to meet tamper-resistant requirements.

When the new forms were ordered, the old, non-compliant ones were stored away on shelves. However, some of these were still occasionally used, Myers says, and reordering of new forms was not made uniform throughout the health system.

Last year, a routine DHMH audit of the outpatient pharmacy at Hopkins Bay view found that nearly half of its prescriptions—47 percent—was written on non-compliant forms. Although the vendor  insisted that the forms it provided complied with the tamper-resistant measures, a subsequent review of the DHMH findings revealed one of the required features was missing.

The state health department’s Office of Inspector General imposed a fine on Bayview for the non-compliant prescription forms. It also informed all community pharmacies that if they received noncompliant prescription forms from a physician, the medication order wasn’t to be filled until the physician could be contacted directly to guarantee that he or she did, indeed, write the prescription—a requirement which inconveniences patients and doctors. In addition, it demanded a refund of all Medicaid revenue Hopkins pharmacies received on prescriptions that were written on noncompliant forms.

Earlier this year, a 20-member performance improvement group began working on a solution. It is championed by Redonda Miller, Hopkins Hospital’s vice president for medical affairs; Eric Aldrich, Howard County General Hospital’s vice president for medical affairs, who represents Hopkins’ community-based hospitals; Krista Decker, Johns Hopkins Home Care Group’s performance-improvement coordinator; Pamela Owens, Deputy Chief Compliance Officer; and Myers.

An internal audit of all six Hopkins-owned outpatient pharmacies—where some 250 Medicaid prescriptions are filled daily—has identified other locations where noncompliant prescription forms were used, Myers says.

 Although the initial attention has been focused on hospitals where Hopkins owns the pharmacies, the compliance rules apply to all pharmacies in Hopkins-affiliated hospitals—including Suburban, Sibley Memorial and All Children’s.

 Neil A. Grauer