Tennessee Pharmacists Association

On Monday, May 19th, the Centers for Medicare and Medicaid Services (CMS) issued a final rule that will make changes to the Medicare Advantage and Medicare Part D prescription drug benefit programs’ regulations. This rule is the final form of a rule that was first proposed publicly in January 2014 and was highly debated. TPA member pharmacists, staff, and patients, as well as the Tennessee Pharmacists Association, submitted multiple comments and letters to CMS in support of the original provisions contained within the Proposed Rule. Unfortunately, many of the provisions in the Proposed Rule were not finalized at this time. One key provision removed from the Final Rule was the Expansion of the Medication Therapy Management (MTM) Services program.

  • Expansion of MTM: While the final rule did not expand patient eligibility and access to pharmacist-provided MTM services, CMS stated that “MTM has been shown to improve drug therapy outcomes and lower costs, and we agree that the use of community-based resources for providing MTM services shows promise in improving access and quality.” CMS also stated that “we still have concerns that many sponsors are applying restrictive criteria to narrow the pool of targeted beneficiaries for MTM rather than optimizing the eligibility criteria to offer MTM to beneficiaries who will most benefit from these services… not enough is being done by sponsors to provide sufficient access to MTM services and engage beneficiaries and providers in this process.”

While many of the provisions in the Proposed Rule were removed from this Final Rule, CMS did hseveral important provisions related to pharmacy practice. 

  • Increased price transparency for network pharmacies: The final rule requires increased price transparency for network pharmacies and requires Part D plans and their pharmacy benefit managers to make available to contracted pharmacies the reimbursement rates for drugs under Maximum Allowable Cost pricing standards.  This requirement will become effective beginning with contract year 2016.
  • Expanded prevention and health improvement incentives: The final rule expands rewards and incentive programs that focus on activities that promote improved health and efficient use of health care resources, as well as prevent injuries and illness. These rule changes will encourage Medicare beneficiaries to participate in rewards and incentive programs, and as pharmacists continue to actively pursue “provider” status at the federal level, more opportunities may arise for pharmacists to provide these valuable care services.

TPA would like to thank all of our members that submitted comments and letters to CMS in support of the language contained within the Proposed Rule. TPA, in collaboration with the National Community Pharmacists Association, the National Alliance of State Pharmacy Associations, and other national association partners, will continue to educate legislators at the state and federal levels about the need for ongoing PBM transparency and the importance of protecting patient access to pharmacist-provided care, and encourages members to do so as well.

To access the CMS fact sheet on this Final Rule, click HERE. To read the complete 487-page CMS Final Rule, click HERE [[http://www.ofr.gov/(X(1)S(02f5b2mbxhxzbhttfo5ubmak))/OFRUpload/OFRData/2014-11734_PI.pdf]].