Friday, June 21, 2013

Prescription Requirements in Pennsylvania

Each state has its own requirements for spectacle, contact lens and pharmaceutical prescriptions. In Pennsylvania, prescription requirements are contained in several sections of the Pennsylvania Code. In addition, there are federal regulations for contact lens prescriptions and separate requirements for tamper-resistant pads for prescriptions written for Medicaid recipients. While some requirements are common among the three types of prescriptions optometrists write, others are specific.



All optometric prescriptions

Pursuant to the Pennsylvania Code, Title 49, Professional and Vocational Standards, Chapter 23, State Board of Optometry, Section 23.72 (a), all optometric prescriptions must bear:

  • Doctor’s name, address. telephone number, fax number and license number.
  • Name of the patient
  • Date the prescription is issued
  • Expiration date

As a side note, NPI numbers do not need to be included on prescriptions.


Spectacle prescriptions

Section 23.72 (d) requires that “Spectacle prescriptions shall specify any information that would be relevant to manufacturing glasses including the dioptic value of the sphere, astigmatism, prism, slab off, add power and axis or orientation of the astigmatism correction. The expiration date of a spectacle prescription may not be greater than 2 years.


Contact lens prescriptions

Section 23.72 (b) requires that “Contact lens prescriptions shall specify the lens type, the specifications necessary for the ordering and fabrication of the lenses, number of refills and expiration date consistent with the type and modality of use of the contact lens being prescribed, but the expiration date may not be greater than 1 year. The prescription may include a statement of caution if the statement is supported by appropriate findings and documented in the patient’s medical record.”

Contact lens expiration dates are also addressed in the FTC’s Contact Lens Rule, the Fairness to Contact Lens Consumers Act (FCLCA) passed on February 4, 2004, which imposes a minimum one year expiration date. There is an exception, however: “A prescriber may set an expiration date of earlier than one year only if that date is based on the prescriber’s medical judgment about the patient’s eye health. In these cases, the prescriber must document the medical reason for the shorter expiration date with enough detail to allow for review by a qualified medical professional, and maintain the records for at least three years.”

The FTC Contact Lens rule also requires that the date of the exam, in addition to the issue date of the prescription, be included on the prescription.


Pharmaceutical prescriptions

Section 23.72 (c) requires that “Pharmaceutical prescriptions shall specify the name of the drug prescribed, quantity and potency prescribed, expiration date, number of refills allowed, instructions for use and any indicated precautionary statements.”

Optometrists are also required to comply with prescription requirements in another section of the Pennsylvania Code: Title 28, Health and Safety, Chapter 25, Controlled Substance, Drugs, Devices and Cosmetics, Section 25.53, Prescription Orders. This section of the Pennsylvania Code provides additional regulations for all providers. Written prescriptions for drugs must be imprinted with the words “substitution permissible and contain one signature line for the physician’s signature. Also required to be imprinted conspicuously on prescription blanks in 8-point, upper-case print are the words: “IN ORDER FOR A BRAND NAME PRODUCT TO BE DISPENSED, THE PRESCRIBER MUST HANDWRITE “BRAND NECESSARY” OR “BRAND MEDICALLY NECESSARY” IN THE SPACE BELOW.”

In addition to the information required on all optometric prescriptions, Section 25.53 also requires that prescriptions for controlled substances must be written in indelible ink, indelible pencil or typewriter; must include not only the name but also the address of the patient; and must include the doctor’s DEA number. DEA numbers cannot be preprinted on the prescription blank, however. Doctors may preprint a line for the DEA number (i.e. “DEA #___________”), but the DEA number itself must be handwritten on the prescription.


Tamper resistant pads

While Pennsylvania has no requirement for tamper-resistant pads, Section 7002(b) of the U.S. Troop Readiness, Veterans’ Care, Katrina Recovery, and Iraq Accountability Appropriations Act of 2007 requires that prescriptions for all Medicaid patients be written on tamper resistant pads. Doctors must consider the number of Medicaid patients they see to determine if they need to order tamper resistant pads or opt instead to phone in prescriptions for their Medicaid patients.


One Rx pad or several?

Whether you have three separate prescription pads for spectacles, contacts and pharmaceuticals or just one pad that can be used for any prescription is a personal business decision. Doctors may use one pad for all prescriptions so long as all of the required imprinted information for all types of prescriptions is included, and all remaining information required for a valid prescription is handwritten.


Ordering through POA

Members practicing in Pennsylvania can purchase prescription pads, including tamper resistant pads, through POA. We can answer your questions about what must and must not be included and guide you through the process. Visit http://pennsylvania.aoa.org/x7793.xml for more information, or contact Joyce at (717) 233-6455 or Joyce@poaeyes.org.