Urgent information for providers
A state law requires all licensed prescribers to use approved tamper-resistant pads and paper when doing hard copy, written prescriptions.
See our frequently asked questions for:
- Pharmacists
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What is approved tamper-resistant prescription paper or pads?
Tamper-resistant prescription paper or pad means a prescription pad or paper that contains one or more industry-recognized feature to prevent each of the following characteristics, and is approved by the Washington State Pharmacy Quality Assurance Commission (Commission):
- 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 from the federal Medicaid tamper-resistant prescription requirements?
The paper or pads must meet the same security features as required by the Centers for Medicare and Medicaid Services; however, Washington State requires that the qualifications for the paper be approved by the Commission. The Commission's approval is acknowledged by "affixing" the Commission's seal of approval.
Who must comply?
All practitioners with prescriptive and dispensing authority must comply with this law, including prescriptions written by veterinarians for written prescriptions for dispensing by a pharmacist, except when exempted by law.
If a pharmacy receives a prescription form that doesn't comply with the law and the prescription cannot be verified with the provider at the time, may the pharmacy dispense the medication on an emergency basis?
Yes, if in the professional judgment of the pharmacist an emergency need for the medication has been demonstrated, the pharmacist may dispense enough medication to last until a prescriber can be contacted (WAC 246-869-100).
Note: Other federal or state restrictions/ or limitations may apply for controlled substance prescriptions.
Are there exceptions in the law when tamper-resistant prescription paper or pads aren't required?
Yes, there are exceptions. Tamper-resistant prescription paper or pads aren't required when:
- Prescriptions are transmitted to the pharmacy electronically, by telephone or by facsimile.
- Prescriptions 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 or limitations may apply for controlled substance prescription.
Do transferred prescriptions need to be on tamper-resistant pads or paper?
The pharmacy needs to receive a phone call or fax from the other pharmacy that originally received the prescription to confirm its authenticity. The receiving pharmacist isn't required to get confirmation of the original prescription from the prescriber.
Will prescriptions printed from a computer need to be on commission-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 commission-approved tamper-resistant paper.
Prescriptions printed using a plain paper software or printing solutions that prints the security features on the paper must be approved by the Commission before the system may be used or marketed in Washington and may not add the Commission's seal of approval until authorized.
The law exempts the use of approved tamper resistant prescription paper when the prescription is delivered to the pharmacy using an approved electronic prescription transmission system, by telephone or by facsimile.
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.
Do transferred prescriptions need to be on tamper-resistant pads or paper?
The pharmacy needs to receive a phone call or fax from the other pharmacy that originally received the prescription to confirm its authenticity. The receiving pharmacist isn't required to get confirmation of the original prescription from the prescriber.
May a pharmacist dispense a prescription written on faxed tamper-resistant pads or paper where the security pantograph is activated?
Prescriptions that are transmitted to the pharmacy by telephone, facsimile, or electronic means aren't required to be on approved tamper-resistant paper. (Refer to law for other exceptions RCW 18.64.500.)
Prescribers should not 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."
However, a pharmacist using his or her professional judgment may dispense a prescription received by fax where the security pantograph is activated by contacting the prescriber for confirmation. Documentation of the call will bring the prescription into compliance.
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 nursing home prescriptions required to be written on commission-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 handle the written order.
What does Commission-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 Pharmacy Commission 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.
- Effective March 1, 2017 the state map is no longer required to be in green thermo chromic ink that changes from green to yellow when exposed to heat or friction.
- Stock barring the previous commission seal of approval may be accepted allowing practitioners to use up their current stock.
See the sample prescription form with the updated seal (PDF).
Washington State Tamper-Resistant Prescriptions Federal Medicaid Tamper-Resistant Prescriptions All written prescriptions must be written on Pharmacy Commission-approved tamper-resistant prescriptions. * All written prescriptions for covered outpatient drugs that are paid for by Medicaid must be written on tamper-resistant prescriptions. Approved tamper-resistant prescription paper or pads must include the following: - One or more feature to prevent unauthorized copying of a completed or blank prescription form.
- One or more feature to prevent erasure or modification of information written on the prescription by the prescriber.
- One or more feature to prevent counterfeit prescription forms.
- Pharmacy Commission seal of approval.
Approved tamper-resistant prescription paper or pads must include the following: - One or more feature to prevent unauthorized copying of a completed or blank prescription form.
- One or more feature to prevent erasure or modification of information written on the prescription by the prescriber.
- One or more feature to prevent counterfeit prescription forms.
- Prescribers
-
What is approved tamper-resistant prescription paper or pads?
Tamper-resistant prescription paper or pad means a prescription pad or paper that contains one or more industry-recognized feature to prevent each of the following characteristics and is approved by the Washington State Pharmacy Quality Assurance Commission (Commission):
- 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 in determining compliance.
Is the Washington State law different from the federal Medicaid tamper- resistant prescription requirements?
The paper or pads must meet the same security features as required by the Centers for Medicare and Medicaid Services; however, Washington State requires that the qualifications for the paper be approved by the Commission. The Commission's approval is acknowledge by "affixing" the Commission's seal of approval.
Washington State Tamper-Resistant Prescriptions Federal Medicaid Tamper-Resistant Prescriptions All written prescriptions must be written on Pharmacy Commission-approved tamper-resistant prescriptions. * All written prescriptions for covered outpatient drugs that are paid for by Medicaid must be written on tamper-resistant prescriptions. Approved tamper-resistant prescription paper or pads must include the following: - One or more feature to prevent unauthorized copying of a completed or blank prescription form.
- One or more feature to prevent erasure or modification of information written on the prescription by the prescriber.
- One or more feature to prevent counterfeit prescription forms.
- Pharmacy Commission seal of approval.
Approved tamper-resistant prescription paper or pads must include the following: - One or more feature to prevent unauthorized copying of a completed or blank prescription form.
- One or more feature to prevent erasure or modification of information written on the prescription by the prescriber.
- One or more feature to prevent counterfeit prescription forms.
Who must comply?
All practitioners with prescriptive and dispensing authority must comply with this law, including prescriptions written by veterinarians for written prescriptions for dispensing by a pharmacist, except when exempted by law. (RCW 18.64.500).
Note: The law is intended to increase patient safety and to stop people from stealing or altering existing prescriptions. Prescriber has a responsibility to safeguard all prescription pads and paper from theft.
Are there exceptions in the law when tamper-resistant prescription paper or pads are not required?
Yes, there are exceptions to the law. Tamper-resistant prescription paper or pads are not required when:
- Prescriptions are transmitted to the pharmacy electronically, by telephone or by facsimile.
- 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.
Will prescriptions printed from a computer need to be on commission-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 commission-approved tamper-resistant paper.
Prescriptions printed using a plain paper software or printing solutions that prints the security features on the paper must be approved by the Commission before the system may be used or marketed in Washington and may not add the Commission's seal of approval until authorized.
The law exempts the use of approved tamper-resistant prescription paper when the prescription is delivered to the pharmacy using an approved electronic prescription transmission system, by telephone or by facsimile.
Note: Other federal or state restrictions/limitation may apply for controlled substance prescription.
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 commission-approval of tamper-resistant paper or pads?
The Pharmacy Commission has developed a review and approval process for vendors seeking approval of their TRPP.
Vendors seeking approval of plain paper print solutions must appear before the commission to demonstrate compliance with the law. Requests for consideration must be received at least 60 days before the next business meeting.
Are nursing home prescriptions required to be written on commission-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 are considered "tamper-resistant," so long as the patient never has the opportunity to handles the written order.
What do Pharmacy Commission-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 Pharmacy Commission 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.
- Effective March 1, 2017 the state map is no longer required to be in green thermo chromic ink that changes from green to yellow when exposed to heat or friction.
- Stock barring the previous commission seal of approval may be accepted allowing practitioners to use up their current stock.
- See the sample prescription form with updated seal (PDF).
Where can a prescriber purchase or acquire commission-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 commission-approved tamper-resistant prescription paper or pads. The Pharmacy Commission doesn't endorse, credential or otherwise certify vendors. The commission simply reviews and approves tamper-resistant paper and authorizes the application of the commission's seal to acknowledge the approval. For more information, contact commission staff members at WSPQAC@doh.wa.gov.
Can a prescriber purchase/acquire blank stock of commission-approved tamper-resistant prescription paper or pads for printing in the office using an electronic medical records system or other means?
Yes, the law doesn't prohibit this practice. It's a business decision for a vendor to provide legitimate requestors with blank stock of the commission-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 the sample prescription form with updated seal (PDF) 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 with updated seal (PDF) for information on what should be included on a prescription form.
- Vendors – Paper suppliers, printers, and printing technology solutions
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What is approved tamper-resistant prescription paper or pads?
It is a prescription pad, paper or print technology that has been approved by the Pharmacy Commission for use in Washington and includes 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.
What is the process for seeking commission approval of tamper-resistant paper or pads?
The Pharmacy Commission has developed a process for vendors to follow to receive the authority to apply the commission's seal to approved tamper-resistant paper/pads that meet the criteria set forth in law (Tamper-Resistant Rx Review/Approval Process (PDF).
Vendors seeking approval of plain paper print solutions must appear before the commission to demonstrate compliance with the law. Requests for consideration must be received at least 60 days before the next business meeting.
Tamper-resistant paper must be approved by the Pharmacy Commission before marketing or sale of pads or paper in Washington State.
Will the Washington State Pharmacy Quality Assurance Commission endorse, credential or otherwise certify vendors whose paper meets the requirements of the law?
No.
What does the Pharmacy Commission seal of approval look like?
- Washington State outline map is centered within a mortar and pestle watermark behind the seal.
Note: Effective March 1, 2017 the state map is no longer required to be in green thermo chromic ink that changes from green to yellow when exposed to heat or friction. - Stock bearing the previous commission seal of approval may be used, allowing practitioners and suppliers to use up their current stock.
- See the sample prescription form with updated seal (PDF).
May vendors provide blank stock of commission-approved tamper-resistant paper or pads to a prescriber or another vendor?
Yes, the law doesn't prohibit this practice. It's a business decision for a vendor to provide legitimate requestors with blank stock of the commission-approved tamper-resistant paper (with the seal affixed) for the prescriber or another vendor for printing prescription- and prescriber-specific information.
Are there specific requirements for prescription forms such as size or format?
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).
There are no regulations on the size or layout of a prescription form with the exception to the seal and the two signature lines. See the sample prescription form w/seal (PDF) for information on what should be included on a prescription form.
When using NCR or carbonless duplicate forms, must the seal of approval be printed on the original and the copy?
No. The seal must appear in original form. It's not required on a copy. The seal symbolizes that the paper is commission-approved and meets the tamper-resistant requirements state in the law. The copy must unmistakably be recognizable as a copy of the original.
Review the tamper-resistant prescription law
See the process for approval of tamper-resistant paper (PDF)
Sample prescription form (PDF)
Important notes
The Washington State Pharmacy Quality Assurance Commission has updated its “seal of approval” for tamper resistant prescription paper that is approved for use when writing a prescription in Washington State.
The updated design of the seal is comparable to the original introduced in 2010, with one significant change. The new seal will still include the mortar and pestle as an artificial watermark and an outline of the state map, but it will no longer require green thermochromic ink. The commission hopes this change will reduce the cost of printing. Please note any current stock with the old seal is still valid.
The Pharmacy Commission doesn't endorse, credential or otherwise certify any printer or supplier of tamper-resistant paper. The commission simply reviews and approves paper or printing technology acknowledging the paper or print technology meets the security features in the law, and authorized the application of the commission's seal of approval.
Pharmacy Commission-approved tamper-resistant prescription paper is widely available. See the sample prescription form above for more prescription format information.
The tamper-resistant paper law doesn't apply to prescriptions delivered to the pharmacy by telephone, by electronic transmission, by fax or for in-patient care. Refer to the law for a full description of exemptions.