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ALBOP Approves Both Sides of a Prescription
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Pharmacies throughout the state have had experiences with charges from PBM auditors and at times with DEA personnel charging that the pharmacy is wrong in recording prescription information on both the front and back of a prescription form. To clarify the Board’s position in this matter, a letter was sent to all registered community pharmacies in the state. The text of that letter is as follows:

The Board has received numerous questions about the legality of placing information on both the front and back of a paper prescription. There are an equal number of concerns expressed about pharmacies being penalized by various audit groups, for using both the back and front of the prescription.  Often such penalties result in the loss of reimbursement, not because the pharmacy made a mistake in preparing and billing the prescription, but rather that they used the back of the prescription to enter information.  As you are well aware, federal law, Title 21, 1306.22 mandates that any refill information be recorded on the back of the prescription.  Obviously, precedent was set years ago for the use of the reverse side of the prescription form.

During the June 17, 2015 meeting of the Alabama State Board of Pharmacy, Board member, Buddy Bunch proposed a discussion of this ongoing difficulty. After discussion of the concern, the Board voted unanimously to establish this policy:

Alabama pharmacies, may use both the front and back of a prescription, as well as any necessary, required or customary attachments to the prescription, to record information necessary for the correct and safe preparation, interpretation, dispensing, transferring or refilling of that prescription. 

  

The Board offered a number of reasons for this decision:

  • Often there is insufficient room on the front of the form to add information due to the extent of the prescription, or to the amount of information which needs to be added.
  • At times prescribers enter multiple prescriptions on the front of one form.
  • At times it might be possible to squeeze in additional information on the front, but the congestion increases the risk of error due to a misreading.

The Board encourages all pharmacists to use professional judgment when placing information on a prescription to assure others know to read information on the back and to prevent cluttering the front with data that can be misread.

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