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Medicare Updates for Pharmacists
Updated November 26,, 2008
11/26/08
CMS Issues a Reminder to Plans on Long-Term Care Pharmacy
Contracting
CMS issued a
reminder to all
Part D Sponsors yesterday of the requirement to 1) provide
convenient access to network long-term care (LTC) pharmacies to all
of their enrollees residing in LTC facilities, and 2) exclude payment
for drugs that are covered under a Medicare Part A stay.
In the notice, CMS reminds sponsors that in
order to remain compliant with their convenient access requirements,
sponsors must either contract with the LTC facility’s contracted
pharmacy or provide the enrollee with covered Part D drugs via another
network LTC pharmacy. Encouraging enrollees to enroll in another plan
during the annual open election period, or through the special election
period for institutionalized beneficiaries, in lieu of contracting with
an LTC pharmacy to provide covered Part D drugs to a facility’s
residents is not permitted. Such activities on the part of
either the LTC care facility or LTC pharmacy are also prohibited, and
may violate other federal laws.
Furthermore, CMS reminds sponsors that they
will be out of compliance with uniform benefits requirements to the
extent that they agree to particular contracting terms and conditions
that have the net result of creating a non-uniform benefit for plan
enrollees residing in certain LTC facilities. It is very important that,
as sponsors negotiate with LTC pharmacies for inclusion in their
networks, they are acutely aware that they cannot agree to differential
benefits that would result in non-uniform benefits among enrollees in
LTC facilities (e.g., extended transition periods, certain utilization
management edits, or different drug utilization review protocols limited
to LTC enrollees obtaining their drugs from a specific LTC pharmacy).
Plan Reporting of LTC Pharmacy Rebate Data
CMS
released a memo on November 24 informing Part D plans that they are
suspending the current collection of LTC rebate reports for CY2008 and
CY2009 in lieu of a new reporting requirement that will be changed,
effective in 2010. Additionally, CMS announced in the memo their
intention to test the proposed reporting requirements with a small
number of Part D sponsors prior to 2010. Please see the attached memo (mc_memoLTCRebateRptChange_112408.pdf)
to view the proposed new reporting requirement for CY2010, as well as
information about the timing of Part D reporting requirements and the
public comment process.
MemoERx_09.19.08.pdf
Supporting Electronic Prescribing under Medicare Part D
CMS released a memo (click
link above) to Part D Sponsors today providing details about our
expectations for supporting e-prescribing, particularly with respect to
the “initial” e-prescribing standards that become effective April 1,
2009. The memo provides context and background on the foundation and
initial standards, and on the changes expected to be brought about by
the Medicare Improvements for Patients and Providers Act of 2008. We
specifically address our expectations details for implementation of the
NCPDP Formulary and Benefits 1.0 standard, the NCPDP SCRIPT 8.1
Medication History standard, NCPDP SCRIPT 8.1 Prescription Fill Status
Notification (RxFill) standard and requirements for the Individual
Prescriber NPI.
And
Ensuring Adequate Network Pharmacy Participation
E-prescribing in Part
D will not be successful -- and e-prescribers will become frustrated --
if pharmacies are not willing or prepared to implement e-prescribing.
While we believe a significant number of pharmacies currently support
e-prescribing and comply with the Part D e-prescribing standards, we
understand Part D pharmacy access standards may be jeopardized if
sponsors were to contractually mandate all network pharmacies to support
e-prescribing as a condition of participation in their network. Thus, as
outlined in Chapter 7 of the
Prescription Drug Benefit Manual (Section 50.1), Part D sponsors
must allow for exceptions to network pharmacy support for e-prescribing
when it is either impractical or otherwise could jeopardize beneficiary
access.
Additionally, we
clarify that we consider the costs incurred by network pharmacies to
implement e-prescribing and transmit and receive e-prescribing
transactions for Part D covered drugs prescribed to Part D eligible
individuals to be legitimate Part D overhead costs that should be a
factor in developing dispensing fees. It is unlikely that dispensing
fees negotiated prior to a pharmacy’s implementation of e-prescribing
factored into these costs. Therefore, we would expect Part D sponsors to
review network dispensing fees to ensure they appropriately reimburse
pharmacies for these new costs. Alternatively, Part D sponsors could
both address these new costs and incentivize pharmacies to implement
e-prescribing by paying differential dispensing fees.
1/4/07
Reminder: Substitution of Generic
Drugs (click link for details)
12/27/06
Medicaid Drug Pricing Regulation Proposed
HHS Secretary Mike Leavitt announced proposed changes in the
payment for certain prescription drugs in the Medicaid program. These
changes implement provisions of the Deficit Reduction Act of 2005 (DRA)
and are expected to save taxpayers $8.4 billion in state and federal
funds over five years. To view the entire CMS Fact Sheet, please
click here:
http://www.cms.hhs.gov/apps/media/fact_sheets.asp . A copy of the
Regulation Text can be found at:
http://www.cms.hhs.gov/MedicaidGenInfo/downloads/AMP2238P.pdf
11/17/06
Medicare Prescription Drug Plan Guide: How to Choose Your 2007 Plan
Workbooks are available to pharmacies. The workbook was produced
through a collaborative effort of NACDS, NCPA, and American's Health
Insurance Plans (AHIP). There are several ways you can obtain
copies of these books for potential distribution to your Medicare
patients:
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Free copies - A limited
quantity of workbooks are are available to pharmacies. Boxes of 60
are available on a "first come, first serve" basis. Send an email
to
Elizabeth.brooks@ahip.org to obtain your free copies.
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Pharmacies can also
obtain a high-resolution PDF (Adobe Reader) version of the workbook to
print additional copies. Pharmacies can "co-brand" the books by
placing their logo on the back. Please contact Susan Pisano at
spisano@ahip.org.
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Pharmacists can direct
their patients to the website
www.healthdecisions.org/guide where they can view the workbook
themselves, print out their own PDF version, or use an online,
interactive version of the workbook.
11/6/06
Medicare Update:
PowerPoint Presentation
Webpage and
Listserv Information
State MMA
Webpage:
http://www.cms.hhs.gov/States/.
Please email feedback
and suggestions in regards to the State MMA Webpage to
MMAStatesWebsite@cms.hhs.gov.
To
subscribe to this listserv, go to
http://www.cms.hhs.gov/apps/mailinglists/default.asp?audience=14 .
Enter your information, then select the appropriate list serve
"MMA_States" and choose subscribe. To unsubscribe from this listserv, go
to
http://www.cms.hhs.gov/apps/mailinglists/default.asp?audience=14 .
Enter your information, then select the appropriate list serve
"MMA_States" and choose unsubscribe.
4/11/06
Medicare Survey Polls Nearly
6,000 Pharmacists - 88% call for immediate improvements in Part D
program.
In a comprehensive survey of nearly 6,000 pharmacists only 119 called
the new Medicare Part D prescription drug program a success. Pharmacists
from across the country expressed their views through a survey conducted
by the Pharmacy Society of Wisconsin on behalf of the National Council
of State Pharmacy Association Executives (NCSPAE). Read the
Press Release. Download
Full Report
2/3/06
Testimony of Pharmacist at U.S.
Senate Special Committee on Aging:
"Meeting the Challenges of the Medicare Drug Benefit Implementation"
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