National and State Associations Submit Joint Comments to CMS on Scope of Practice

Last Friday, 47 state pharmacy associations and NASPA joined several national associations and state health-system pharmacy societies in submitting comments regarding the Centers for Medicare and Medicaid Services’ request for input on Executive Order #13890, “Protecting and Improving Medicare for our Nation’s Seniors.” The signing organizations requested CMS include the following changes in agency regulations, programs, and policies to implement the charges outlined in the EO:

General Recommendations

  • Use inclusive provider language in rulemakings, programs, and policies to ensure pharmacist inclusion to support medication optimization and improve patient outcomes.
  • Issue a Center for Medicaid & CHIP Services Information Bulletin where payers could utilize pharmacists to better address needs for patients.
  • Attribute and promote significant contributions of pharmacists to health outcomes of Medicare beneficiaries.
  • Expand service models utilizing pharmacist-provided patient care services using CMS Center for Medicare and Medicaid Innovation data, including in value-based payment models by employing CMMI’s waiver authority.
  • Incorporate and/or test an alternative model at CMMI in rural and medically underserved areas/populations focusing on optimizing medication use and health outcomes as part of coordinated care delivery including pharmacists.
  • Ensure pharmacists can engage in remote patient monitoring and other telehealth services.

Specific Recommendations

  • Implement a general supervision requirement vs. direct supervision for services delivered by highly trained pharmacists.
  • Align Medicare service requirements with the most robust pharmacist state scopes of practice.
  • Clarify physicians and other qualified practitioners can bill for “incident to” services provided to Medicare beneficiaries by pharmacists at levels higher than E/M code 99211.
  • Address challenges for pharmacists and pharmacies to deliver DSMT services and continuous glucose monitoring services.
  • Allow pharmacist-initiated electronic prior authorization.
  • Allow pharmacists to be DATA-waived providers by including as qualified practitioners.

Read Final Joint Comments

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