19.02.2013 Views

Notice: This CMS-approved document has been submitted - Philips ...

Notice: This CMS-approved document has been submitted - Philips ...

Notice: This CMS-approved document has been submitted - Philips ...

SHOW MORE
SHOW LESS

Create successful ePaper yourself

Turn your PDF publications into a flip-book with our unique Google optimized e-Paper software.

<strong>CMS</strong>-1403-FC<br />

pharmacies to follow record retention requirements under<br />

State law.<br />

Response: We appreciate the importance of the<br />

requirements of State boards of pharmacy, however we uphold<br />

that Medicare is a national program and it is necessary to<br />

establish national standards for maintaining the ordering<br />

and referring record retention period. We believe that<br />

this approach will lead to <strong>CMS</strong> consistency. While we are<br />

not changing our record retention policy to account for<br />

different State pharmacy laws, we are revising the proposed<br />

10-year record retention policy and establishing an<br />

ordering and referring record retention period as 7 years<br />

from the date of service<br />

Comment: One commenter believes that pharmacies<br />

should be allowed to maintain their hard-copy records<br />

offsite electronically after a certain time.<br />

Response: The provisions of the final rule do not<br />

preclude offsite or electronic storage as long as these<br />

records are readily accessible and retrievable.<br />

Comment: Several commenters recommended that<br />

pharmacies should maintain the prescription record in<br />

written form for the greater of 3 years or the requirements<br />

in State law, and then allow the prescription to be stored<br />

electronically for the remaining years. The commenter<br />

315

Hooray! Your file is uploaded and ready to be published.

Saved successfully!

Ooh no, something went wrong!