Health Law Blog

Effective October 1, 2011, pharmacy providers must obtain a signature from the beneficiary or their designee confirming receipt of the pharmacy service(s). This policy applies to all pick-ups, home deliveries and facility deliveries. Claim submission is not proof that the prescription or fiscal order was actually furnished.

Provisions of this signature requirement at time of pick up include:

• The signature documentation must also include the prescription number and date the prescription/fiscal order was picked up. If multiple prescriptions are being picked up at one time, a single signature verifying receipt will be sufficient for all of the patient's prescriptions/fiscal orders.
• Electronic signatures for receipt are permitted only if retrievable upon audit and kept on file by the pharmacy.
• Obtaining a signature to confirm receipt of prescriptions/fiscal orders can be part of a counseling log.
• The signature confirmation must be maintained by the dispensing pharmacy for six years from the date of payment and must be retrievable upon audit.

Provisions of this signature requirement for facility delivery include:

• A signature is required at the time of delivery.
• The signature documentation must also include the list of prescription number(s) and date the medication(s) was/were delivered. A single signature verifying receipt will be sufficient for all of the medications in the delivery.
• Electronic signatures for receipt or electronic tracking slips for delivery are permitted only if retrievable on audit.
• A waiver signature form is not an acceptable practice, and such forms will not serve as confirmation of delivery. Waiver signature forms are defined by delivery industry standards.
• Confirmation of the delivery must be maintained by the pharmacy for six years from the date of payment and must be retrievable on audit. Delivery industry tracking receipts that contain a signature (e.g., FedEx tracking receipts) qualify as a signature for receipt of delivery.

For more information on the policy contact our pharmacy attorneys at 718-787-9500 or at This email address is being protected from spambots. You need JavaScript enabled to view it. .