December 9, 2005

In consultation with the various state agencies responsible for the administration of pharmacy benefits, the Governor’s Office of Health Care Reform has reviewed the results of recent pharmacy audits. Based on a review of the audits findings, the Office of Health Care Reform and the affected agencies, after consultation with the State Board of Pharmacy, and the State Board of Medicine, have reached the following policy decisions:

Prior to November 30, 2005, undated non-controlled prescriptions will not be questioned. However, EFFECTIVE JANUARY 2, 2006, CLAIMS WILL BE DISALLOWED on audit, at the Agency’s discretion, if:

The original prescription does not contain the date it was written. Prior to the dispensing of all new or refills of prescription drugs, the pharmacist shall review the original written prescription for noncompliance with prescription writing standards and date the prescription if the prescriber has not dated it. The pharmacist shall use his/her best professional judgment when dating the prescription.

Stamped dates, dates on prescription faxes and electronically transmitted prescription dates are all acceptable.

Letters from the physician’s office obtained after the audit has been conducted or copies of dated pharmacy computer labels will not be accepted as proof of the date the prescription was written.

Also, Providers are reminded that claims will be disallowed on audit if:

The paid claim contains an incorrect prescriber identification number. Corrected prescriber identification numbers will not be accepted after completion of the audit. An accurate prescriber identification number is essential to monitor physician prescribing patterns and to conduct meaningful and efficient review activities. In addition, false or incorrect prescriber identification numbers on pharmacy claim data cause the misdirection of educational interventions necessary to fulfill the federally mandated Retrospective Drug Utilization Review Program.

The required documentation for either an oral or a written prescription is not at the pharmacy at the time of the audit. Prescription documentation will not be accepted after completion of the audit.

OHCRPB-05-01