Using photos to corroborate a prescription

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drjchill
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Joined: Fri Sep 17, 2010 6:32 am
Location: Chillicothe, Ohio

Using photos to corroborate a prescription

Post by drjchill » Mon Apr 15, 2019 2:36 pm

Are there new guidelines or regulations about corroborating a prescription? One of my co-workers recently attended MRO assistant training, and she was told that we are not allowed to use "pictures/images" to verify the validity of a prescription because they can be tampered with (photoshop). I cannot find an exclusion in the CFR for this activity. Personally, the quality of the image is better with the picture than with a "faxed copy."



Robert Swotinsky MD
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Re: Using photos to corroborate a prescription

Post by Robert Swotinsky MD » Mon Apr 15, 2019 6:35 pm

SAMHSA had advised, “A prescription may be verified by means such as photos sent by text, e-mail, or fax showing enough angled shots of the bottle label that the MRO can verify the label, prescription number, name of the drug, prescribing physician, date filled, number of pills in the prescription, number of refills, and the pharmacy name, address and contact information.” [Medical Review Officer Guidance Manual for Federal Workplace Drug Testing Programs. Rockville, MD: Department of Health and Human Services. Eff: October 1, 2017.]

By contrast, DOT has warned, “With the advancement of photography manipulation and enhancement software easily available through the Internet, MROs should speak with the pharmacy and not simply rely on a photograph of the prescription label.” [Department of Transportation. Procedures for transportation workplace drug and alcohol testing programs: Addition of certain Schedule II drugs to the Department of Transportation’s Drug-Testing Panel and Certain Minor Amendments. Federal Register 82 (November 13, 2017):52229-52248.]

I agree with drjchill. If the prescription is unusual or concern is otherwise heightened,it's reasonable to take other and/or multiple steps to corroborate the donor's explanation.

drjchill
Posts: 77
Joined: Fri Sep 17, 2010 6:32 am
Location: Chillicothe, Ohio

Re: Using photos to corroborate a prescription

Post by drjchill » Thu Apr 18, 2019 7:39 am

The MROs have a serious safety duty when verifying the prescription an employee provides to the MRO. Under § 40.141(b), the MRO (and not the MRO’s staff) must ‘‘review and take all reasonable and necessary steps to verify the authenticity of all medical records the employee provides.’’ With the advancement of photography manipulation and enhancement software easily available through the Internet, MROs should speak with the pharmacy and not simply rely on a photograph of the prescription label. That contact with the pharmacy can also shed light on whether there is a significant safety risk posed in the particular situation the MRO is assessing.

Here is the referenced regulation; however, I am unsure about the last sentence!

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