Rethinking the Medicare Part D Medication Therapy Management: Comprehensive Medication Review

What is a Comprehensive Medication Review (CMR)?

“A CMR is an interactive person-to-person or telehealth medication review and consultation conducted in real-time between the patient and/or other authorized individual, such as prescriber or caregiver, and the pharmacist or other qualified provider and is designed to improve patients’ knowledge of their prescriptions, over-the- counter (OTC) medications, herbal therapies and dietary supplements, identify and address problems or concerns that patients may have, and empower patients to self-manage their medications and their health conditions.”¹

Why do CMRs matter?

Medicare Part D prescription drug plans must offer an annual CMR to eligible Medicare beneficiaries. To ensure Part D plans pay attention to this requirement, CMS has included a quality metric, the CMR completion rate, in their Star Ratings. CMS describes this metric to the public as “Members who had a pharmacist (or other health professional) help them understand and manage their medications.” Public reporting of this metric is available on Medicare’s “Explore your Medicare coverage options” website, although it takes several clicks to view the number of stars that the Part D plan received for this measure.

How many Medicare beneficiaries receive a CMR?

Substantial progress has been made since the inclusion of the CMR completion rate measure into Star Ratings in 2016 but CMR completion rates have stalled in recent years (see Figure). When you think of the total Medicare population, only a small percentage receives a CMR. In Star Rating Year 2024, roughly 50 million Medicare beneficiaries were enrolled in a Part D plan; 4.5 million were eligible for MTM services and about 3.2 million received a CMR. This equates to ~6.4% of Medicare beneficiaries receiving a CMR.^2,3,4

Figure. Comprehensive Medication Review (CMR) Completion Rates by Star Ratings Year^3,5,6,7

MA-PD = Medicare Advantage Prescription Drug, PDP = Prescription Drug Plan

Note: Star Ratings are based on data from two years prior. For example, Star Ratings year 2024 is based on data from 2022.

Future directions of the CMR

In 2022, CMS shook the industry by proposing to change the MTM targeting criteria, which was estimated to more than double the number of eligible beneficiaries.⁴ CMS did not implement their proposed changes.

The current MTM targeting criteria does not allow Part D plans to identify beneficiaries that would benefit the most from receiving a CMR. Further support for this can be found in the Enhanced MTM model where Part D sponsors had regulatory flexibility to design their MTM programs. Financial support was available to fund these MTM programs and an added incentive if health care cost targets were achieved. Participating part D plans incorporated the CMR into their programs, but it was only a part of the MTM offerings. When CMRs were offered, they were only offered to some of the MTM eligible population, and with a different structure and frequency than currently required. One participating part D plan discontinued offering CMRs during the model. Additionally, lackluster feelings about repeating an annual CMR have been emerging from some beneficiaries.⁸

Stakeholder interest is high in progressing beyond the current targeting criteria and requirement for an annual CMR, but a significant regulatory hurdle exists. Beyond this hurdle, beneficiary involvement and additional evidence are needed to ensure a beneficiary-centered approach.

References

1. Correction to contract year 2022 Part D medication therapy management program guidance and submission instructions. April 30, 2021. Accessed December 14, 2023. https://www.cms.gov/files/document/memo-contract-year-2022-medication-therapy-management-mtm-program-submission-v-083121.pdf
2. Cubanski J, Damic A. Key facts about Medicare Part D enrollment and costs in 2022. KFF Health. Published August 17, 2022. Accessed December 14, 2023. https://www.kff.org/medicare/issue-brief/key-facts-about-medicare-part-d-enrollment-and-costs-in-2022/
3. Medicare 2024 Part C & D Star Ratings technical notes. Accessed December 14, 2023. https://www.cms.gov/files/document/2024technotes20230929.pdf
4. Medicare program; contract year 2024 policy and technical changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, Medicare Parts A, B, C, and D overpayment provisions of the Affordable Care Act and programs of all-inclusive care for the elderly; Health information technology standards and implementation specifications. Accessed December 14, 2023. https://public-inspection.federalregister.gov/2022-26956.pdf
5. Cooke CE, Olshanskaya S, Lee M, Brandt NJ. Evolution of the comprehensive medication review completion rate for Medicare Part D plans: What do the Stars tell us? Sr Care Pharm. 2022;37(8):357-365. doi:10.4140/TCP.n.2022.357
6. Medicare 2022 Part C & D Star Ratings technical notes. Accessed December 14, 2023. https://www.cms.gov/files/document/2022-star-ratings-technical-notes-oct-4-2022.pdf
7. Medicare 2023 Part C & D Star Ratings technical notes. Accessed December 14, 2023. https://www.cms.gov/files/document/2023-star-ratings-technical-notes.pdf
8. Acumen, LLC. Evaluation of the Part D enhanced medication therapy management (MTM) Model: Fifth evaluation report. CMS. Published February 2023. Accessed December 14, 2023. https://www.cms.gov/priorities/innovation/data-and-reports/2023/mtm-fifth-evalrept