The Medicare Modernization Act of 2003 included a requirement that Medicare Part D sponsors provide medication therapy management (MTM) services to targeted beneficiaries as part of their Medicare drug benefit program. Generally, qualifying beneficiaries include those with multiple chronic conditions taking multiple medications, though other qualifications exist.
The Centers for Medicare and Medicaid Services (CMS) requires all Medicare Part D Plan Providers to include MTM services in their Part D Plans and to define the criteria they will use in identifying and providing services to the targeted beneficiaries.
These requirements create a particular challenge for long-term care (LTC) facilities. Many patients in LTC facilities are dealing with multiple potentially terminal conditions, cognitive impairment, or both. Patients’ goals for treatment may vary, as may the individual who is responsible for making treatment-related decisions for the patient. Further complicating this issue is the broader, similar CMS requirement of a Medication Regimen Review (MRR) for nursing facility residents, which shares common goals with the MTM requirement.
Due to the distinct challenges LTC facilities face in providing MTM services as part if their Part D plans, the ASCP recommends that Medicare Part D plans outline a business relationship with the consultant pharmacist at the LTC facility. Consultant pharmacists in LTC facilities have existing relationships with patients, access to on-site health records, and a demonstrated ability to improve clinical outcomes. Drawing on this existing relationship for MTM services can reduce duplicative or conflicting medical recommendations, reduce costs of plans by using an existing resource, and improve outcomes for LTC facilities, Medicare Part D sponsors, and most importantly, patients receiving MTM services.
The links below provide a comprehensive view of the issues surrounding MTM services, including more information and recent news about MTM, as well as ASCP resources and products to help consultant pharmacists and LTC facilities provide patients with quality MTM services.
ASCP Products and Resources
ASCP Policy Resources
Articles from The Consultant Pharmacist (To view these articles, you will need to log-in to your ASCP Membership account)
Highlights within this document:
News Articles and Press Releases
February 17, 2012—CMS CY2013 Advance Notice and Draft Call Letter Now Available
CMS 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. 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 were due March 2, and the final Advance Notice and Call Letter was published April 2. Members seeking additional information and updates should join the Grassroots Network by emailing email@example.com.
August 2011—MTM Research Questions Advance Under AHRQ’s Systematic Review Process
Research questions on the subject of pharmacist-delivered MTM under consideration at the Agency for Health Research and Quality (AHRQ) are advancing through the agency’s systematic literature review process. AHRQ is a federal research agency under the Department of Health and Human Services, which houses research centers that study health quality effectiveness and improvement. AHRQ is charged with managing the disbursement of grant funding to academic and private sector partners to study a variety of major areas of health care research. The questions submitted to AHRQ by the Pharmaceutical Quality Alliance (PQA) and the Joint Commission of Pharmacist Practitioners (JCPP) will be used to conduct an evaluation called a systematic literature review, through which AHRQ will evaluate the breadth of literature available on pharmacist-delivered MTM and decide whether more resources should be dedicated to studying what could improve patient outcomes and health care quality. The PQA with support from the JCPP nominated a set of questions related to pharmacist-delivered MTM for study and evaluation at AHRQ. Section 3503 of the Affordable Care Act (ACA), known as the MTM Grant program, is unfunded. Research conducted within an AHRQ sponsored research center may be one mechanism for obtaining funding, since the ACA MTM grant program is intended to study the effectiveness of pharmacist-delivered MTM. ASCP has learned that the systematic review will be conducted by an evidence-based practice center, one of their academic research partner sites. This will apparently expedite the review process because they will not have to solicit proposals for vendors. The EPC will review and post the PQA questions for public comment, probably within the next month. Comment period will be 4-6 weeks, and then the questions will be finalized and used to conduct the systematic review for literature. The review will take about 6 months at which time to EPC will issue a report identifying gaps in the literature that could be the basis for
December 11, 2008—ASCP submits White Paper on Medication Therapy Management to Obama Transition Team
With input from ASCP members, ASCP Policy and Advocacy Department developed a white paper, entitled “Medication-related Problems in Older Adults: A Hidden and Costly Epidemic.” This white paper has been submitted to Obama Transition Team staff. Read the document here.
October 2008—ASCP Comments to CMS on HIPAA Electronic Transaction Standards for Billing Pharmacists' Professional Services
CMS released a Notice of Proposed Rule Making (NPRM) on August 22, 2008, that proposed pharmacists' professional services be billed either via the NCPDP Telecommunication standard (the way medications are billed by pharmacies now) OR the X-12 standard (the way physicians and other health care professionals bill for their services). Previously, CMS said professional services could only be billed using X-12, so their August 22 proposal was a departure from their previous decision.
Using the NCPDP standard helps pharmacies who want to integrate billing medication therapy management services into their current work flow, but the X-12 standard must remain an option for those pharmacists who do not work in a pharmacy. ASCP cautiously agreed with CMS' proposal to use either standard, but ASCP urged CMS to adopt policies ensuring complete separation of product billing from service billing.