AMCP Comments on Proposed CMS Changes to Part D Reporting Requirements

Future changes to Part D Reporting Requirements proposed by the Centers for Medicare & Medicaid Services (CMS) for contract year 2013 may pose new challenges to Part D plan sponsors if enacted. Responding to a request by CMS for comments on the proposed changes, the Academy of Managed Care Pharmacy (AMCP) issued a letter to CMS in January 2012 responding to a number of potentially problematic issues particularly in 2 areas: Long-Term Care (LTC) Utilization and Waste (or currently referred to as Unused Drugs in Long-Term Care) and medication therapy management (MTM) programs. Unused Drugs in Long-Term Care Under the proposed changes, all long-term pharmacies in LTC facilities will be required to dispense Part D brand name drugs in increments of ≤14 days. Of concern to AMCP is implementation of this new regulation that will mandate Part D plan sponsors to collect information from their network LTC pharmacies to determine the amount of unused brand and generic drugs. Although recognizing the need for data collection efforts, AMCP emphasized to CMS that data collection places a significant burden on both LTC pharmacies and Part D sponsor plans. Among the challenges is the requirement that Part D plan sponsors report unused brand and generic drugs to CMS at least biannually. Under this mandate, LTC pharmacies would have to calculate the number of tablets or capsules remaining for each discontinued prescription and provide this data to each Part D plan. Each Part D plan in turn would have to aggregate the data and send a prepared report to CMS biannually. One main problem highlighted by AMCP is the lack of standardization of data collection among pharmacies that will result in CMS receiving imprecise data. Emphasizing that the quality and integrity of reported data suffer without a standard format and infrastructure for reporting, the academy asked CMS to work with the Council for Prescription Drug Programs on development of a reporting standard. “The academy asks CMS to continue to address challenges in data collection and data accuracy as it finalizes these reporting requirements,” wrote Edith A. Rosato, RPh, IOM, chief executive officer, AMCP, on behalf of the academy. MTM Programs Several potential changes to MTM programs were addressed by the academy. One proposed change is the use of data element U to collect data on the number of drug therapy problem recommendations made as a result of MTM services to help CMS assess the value of Part D MTM programs. Although acknowledging the importance of this data element to demonstrate the extent of a plan’s comprehensive medication reviews (CMRs) and the positive contributions provided by Part D MTM providers, AMCP is concerned with the potential use of this data element along with what it assumes will be the use of data element V to provide data on the number of drug therapy problem resolutions made as a result of MTM recommendations. According to the academy, using these 2 data elements to calculate the impact of MTM programs is problematic and may not adequately or appropriately measure the impact of MTM interventions. AMCP also is suggesting the postponement of the creation of a new data element (S), which would provide data on recipients of interactive CMRs in LTC facilities. Under the Patient Protection and Affordable Care Act (ACA), Part D plan sponsors must offer the annual CMR for target beneficiaries in an LTC facility. Acknowledging that CMS must revise current regulations to comply with this ACA provision, the academy feels, however, that the creation of a new data element to measure this new provision before the final regulation takes effect is confusing and should be postponed until after the final regulations are in place. Finally, AMCP is opposing any type of requirement that would mandate direct or indirect contracts between Part D plan sponsors and consumer pharmacists to, according to CMS, help ensure better care coordination and cost efficiencies. “Part D plans should consider LTC consultant pharmacies as important resources for providing MTM services,” wrote Dr. Rosato. “However, the ultimate decision on who is providing those services is a contract decision that should be made by the plan.”