Changes for MTM, short-cycle dispensing in final rule; NPI clarification in call letter.
Taking steps to improve Medicare that APhA supports, CMS has released a final rule on revisions to Medicare for 2012 and the Final 2012 Advance Notice and Call Letter on changes to Medicare Advantage and Medicare Part D for 2012.
The final rule, released on April 5, implements part of the Affordable Care Act (ACA) and will be published in the Federal Register on April 15. The pharmacy-related provisions include medication therapy management (MTM) programs and short-cycle dispensing in long-term care facilities (LTCFs). CMS released also released fact sheets on the rule.
Regarding Medicare Part D MTM programs, the final rule reconciles ACA provisions with existing regulations that were effective in 2010. The plans’ MTM benefit for targeted beneficiaries must continue to have opt-out enrollment for MTM services in addition to including an annual comprehensive medication review (CMR), targeted medication review, and summary of the patient’s visit, according to Marcie Bough, PharmD, APhA’s Senior Director, Government Affairs. Effective January 1, 2013, patients receiving a CMR will be provided a Medication Action Plan (MAP) in a standardized format. Plans will also be required to perform a quarterly assessment of all “at risk” individuals not already enrolled as a targeted beneficiary in an MTM program. CMS did not finalize MTM-related provisions for LTCFs, and will work with stakeholders on those.
Implementing short-cycle dispensing in LTCFs was delayed by 1 year to January 1, 2013. APhA supports this delay, Bough said. Dispensing will be limited to 14-day increments for solid oral doses of covered brand-name drugs, with some exclusions. The reporting requirement for unused drugs in 7-day-or-less increments will be waived. Also, total cost-sharing for copayments cannot be more than what would be imposed without this provision.
Other changes in the final rule to Medicare for 2012 include standardization of the exceptions and appeals process for plans, revisions to the definition of “pharmacist,” payment for multi-ingredient drug compounds, and the continued steps in the closing of the Part D coverage gap.
APhA addressed the above topics in January 11 comments to CMS on the proposed regulations. APhA also thanked CMS for aiming to improve the Medicare Part D program based on lessons learned and stakeholder feedback. APhA commented to CMS on March 25 on the proposed standardized MAP.
CMS on April 4 issued the Final 2012 Advance Notice and Call Letter with a fact sheet. The subregulatory guidance’s pharmacy-related areas include clarification on the use of prescriber identifiers on Part D claims and an earlier Annual Coordinated Election Period and enrollment.
Regarding the issue of prescriber identifiers in 2012, CMS will continue to allow the use of National Provider Identifier (NPI) numbers, DEA numbers, unique provider identification numbers, or state license numbers. For 2013, CMS is considering a regulatory change that would only allow NPI numbers as the prescriber identifier on claims. In addition, plans will be required to confirm the validity of DEA numbers on claims for controlled substances or map NPIs on these claims to the prescriber’s DEA number, as well as confirm that the controlled substances is within the prescriber’s scope of practice.
For 2012, the Annual Coordinated Election Period and enrollment will move earlier in the year, starting October 15, 2011, and ending December 7, 2011. The call letter included other changes to pharmacy-related areas, including reference to quality measures related to work being done by the Pharmacy Quality Alliance (PQA).
In APhA`s March 4 comments to CMS on the draft call letter, APhA noted that pharmacies cannot always obtain a prescriber’s NPI number at the time of dispensing. In APhA’s January 11 comments to CMS, APhA supported the revised dates for the Annual Coordinated Election Period and enrollment because an earlier closing date would “better ensure that “correct beneficiary enrollment information is available at the pharmacy beginning January 1 of a plan year.”
Related resources on www.pharmacist.com
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