In March 1 comments to CMS, APhA supported the agency’s dialogue on medication therapy management (MTM) services and continuing efforts to improve and expand the Medicare Part D MTM program included in the CMS draft advance notice and call letter for 2014.
CMS will release the final guidance for Medicare Advantage and Part D prescription drug plans on April 1, 2013.
The agency’s ongoing efforts to improve the Part D MTM program and to expand the number of patients using MTM services were a major theme throughout CMS’s combined draft guidance document. APhA’s comments supported these efforts, including the following:
Throughout the draft guidance, CMS referenced and encouraged support for the U.S. Department of Health & Human Services’s Million Hearts initiative to prevent 1 million heart attacks and strokes by 2017. APhA and the APhA Foundation are partners in Million Hearts, and are actively engaged in encouraging involvement of pharmacists and student pharmacists nationwide.
APhA’s comments recommended that CMS encourage plans to use pharmacists in providing MTM services and other patient health and wellness services as part of plans’ efforts to meet and improve quality measures and Star Ratings, and (as CMS discussed) to use MTM services to engage in Million Hearts.
The Association’s comments supported CMS’s continued use of PQA (Pharmacy Quality Alliance) measures as part of the Star Ratings system and revisions to the methodology of current measures related to PQA-endorsed use of High-Risk Medications in the Elderly measures and Medication Adherence for Diabetes Medications (Part D). The comments also supported proposed new 4-star threshold measures for Part C and D measures related to all-cause readmissions and medication adherence for diabetes, hypertension, and cholesterol medications.
The Association’s comments additionally supported CMS encouraging plans to adopt standardized health information technology (HIT) for documentation of MTM services and encouraged CMS to work with the Pharmacy e-HIT Collaborative, which is leading efforts to integrate pharmacist-provided patient care services into the national HIT interoperable framework.