Comprehensive Medication Reviews

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Comprehensive Medication Reviews in the Long-term Care Setting

In an April 2012 Federal Register notice, the Centers for Medicare and Medicaid Services (CMS) clarified requirements for all Part D plan sponsors, as part of their medication therapy management (MTM) benefit, to offer an annual comprehensive medication review (CMR) to all qualifying beneficiaries, including those in long-term care. All part D plans must comply with this standard effective January 1, 2013. The final rule specified that if beneficiaries qualifying for the comprehensive medication review have cognitive impairments that prevent them from participating directly in the CMR.


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  • CMS Continues Efforts to Expand MTM in Long-Term Care (April 2012).

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News Articles and Press Releases

April 12, 2012 - CMS To Require Annual Medication Review Under Medicare Part D
Beginning January 1, 2013, Medicare Part D plan sponsors will be required to offer qualifying beneficiaries an annual comprehensive medication review (CMR). This provision for medication therapy management (MTM) benefit was published in an April 12 Federal Register notice. CMS said that the benefit is opt-out only, and long-term care residents are not exempt. Patients must receive at minimum an annual CMR, which must be face-to-face or through the use of telehealth technologies. A pharmacist or any other qualified provider may perform the CMR. CMS instructs Part D plan sponsors to work with consultant pharmacists to determine whether a beneficiary is able to participate in his or her CMR and to prevent overlap or conflict between the CMR benefit and monthly drug regimen reviews. CMS plans to issue further guidance to Part D plan sponsors on implementing this requirement and service level expectations.

February 17, 2012 - CMS CY2013 Advance Notice and Draft Call Letter Now Available
The Centers for Medicare & Medicaid Services (CMS) on February 17 issued the draft Advance Notice of Methodological Changes for Calendar Year (CY) 2013 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2013 Call Letter (Advance Notice and Call Letter, PDF). The Advance Notice contains proposed changes in rate calculations for Part C plan sponsors, changes in payment methodology for original Medicare benefits and rebate obligations, and changes in payment methodology for CY2013 Part D benefits. The draft Call Letter contains among other things proposed changes to plan benefit requirements for Prescription Drug Plan (PDP) sponsors submitting bids for CY2013. The draft Call Letter contains several proposals of interest to ASCP members including changes to Medication Therapy Management (MTM) benefits and enforcement of Drug Utilization Review (DUR) and Drug Utilization Management (DUM) programs. Comments are due March 2. The final Advance Notice and Call Letter will be published April 2. Members seeking additional information and updates should join the Grassroots Network by emailing

December 2010 - Spotlight: CMS Proposes MTM Requirement in LTCFs in Conjunction with MRRs
Included in the proposed rule outlining requirements for 7-days-or-less dispensing requirements for Part D covered drugs in long-term care, CMS proposes improvements to medication therapy management (MTM) programs. In the proposed rule published November 22, CMS proposes to require Part D plans to contract with LTC facilities to provide MTM services to residents in coordination with monthly medication regimen reviews (MRR) performed by consultant pharmacists. If finalized, this requirement would become effective January 1, 2013. CMS is seeking comments from the industry on how Part D plans and LTC facilities can best coordinate. In addition to proposing MTM requirements for long-term care residents, CMS is also proposing Part D plan sponsors use a standardized format for the written summary and action plan resulting from an annual comprehensive medication review (CMR). Part D plans must also provide beneficiaries with a copy of the CMR. To facilitate this requirement, CMS will work with stakeholders and contract with a third party to develop a standardized format for the written summary and action plan. The proposed rule also codifies the use of telehealth technologies to conduct the required annual CMR. ASCP will be submitting comments in response to this provision in the proposed rule. You can share your feedback with us by sending an e-mail to

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