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Pharmacy and Provider Lock-in Programs in Medicaid Fee for Service

Lock-in programs, sometimes referred to as patient review and restriction programs, require patients considered at risk for misuse of certain drugs to obtain and fill prescriptions from predesignated pharmacies and prescribers. Such at-risk patients are identified through criteria that may include the number of prescriptions and pharmacies they have visited to obtain controlled substance prescriptions within a certain time frame.

This issue brief begins with background on the federal regulation of lock-in programs. It then describes the variation across states on several dimensions, including how states account for federal regulatory requirements; whether beneficiaries are restricted to a designated pharmacy, prescriber, or both; the criteria states use to lock in beneficiaries; the timeframe beneficiaries are locked in; and the number of beneficiaries affected by these programs. The brief concludes with a discussion of how beneficiaries may circumvent lock-in programs through out-of-pocket payments for controlled substances.

State specific lock-in policies for both fee for service and managed care, and other policies specific to controlled substances can be found in our compendium of state drug utilization policies.