APhA to CMS: Feedback on MTM, Million Hearts, more for 2014

Association comments on draft CMS advance notice and call letter


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Part D MTM program and to expand the number of patients using MTM services were a major theme throughout CMS’s combined draft guidance document.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:

  • CMS wrote, “Growing evidence of the value of MTM to improve beneficiaries’ therapeutic outcomes indicates that more beneficiaries may benefit from these services.”
  • CMS encouraged plans to optimize their MTM programs to those who may benefit the most and stated that plans may also offer MTM services to an expanded population of beneficiaries who do not meet the eligibility criteria.
  • CMS reported that it is aware of high-performing plans using MTM services to improve their Part D Star Ratings, which speaks to the value of MTM services.
  • CMS provided background and summary results of its study looking at MTM services for congestive heart failure and chronic obstructive pulmonary disease patients.
  • CMS referenced MTM as it promotes coordination of care. Related to this, the Association’s comments highlighted that APhA and the American Society of Health-System Pharmacists (ASHP) have released two resources related to care transitions: Improving Care Transitions: Optimizing Medication Reconciliation (March 2012) and ASHP–APhA Medication Management in Care Transitions Best Practices (March 2013).
  • CMS planned to continue to promote beneficiaries’ awareness of MTM services through the 2014 Medicare & You Handbook, on Medicare.gov, through the new MTM tab on the plan finder, and the requirement that plans have a dedicated “Medication Therapy Management Program” page linked from the Medicare drug plan website.

Throughout the draft guidance, CMS referenced and encouraged support for the U.S. Department of Health & Human Services’s Million Hearts initiative to prevent 1 million heart attacks and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.

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