ASCP CEO Reports on Progress to Provide Comments to CMS by June 11, 2012 Due Date

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Responses to the CMS solicitation for public comments regarding the proposed LTC consultant pharmacist independence policy are due to the docket by June 11, 2012. ASCP’s Policy & Advocacy Department is responsible for coordinating the development of ASCP’s comments, which will necessarily include input from several sources. An update on ASCP’s progress toward submitting comments is summarized below, including opportunities for members and leadership to provide feedback to ASCP headquarters in the development of our comments.

  1. The Advocacy Committee (joined by members of the Board, Council of Presidents, key staff and a variety of topical and clinical experts) will meet weekly via teleconference to evaluate and discuss input gathered from members and external sources and the status of the development of the comments.
  2. The monthly Policy & Advocacy Briefing teleconferences scheduled for May 3 and June 7 will focus on the development of ASCP’s comments to CMS. As with all monthly briefings, these calls are open to the full membership.
  3. The Grassroots Network will be kept informed of the progress being made in the development of comments and other related parallel work on a weekly basis. Grassroots Network subscribers will also be solicited for feedback on specific issues and questions through the listserv. To join the Grassroots Network, email
  4. ASCP will develop and launch a member survey based on select key points and questions posed by CMS. The survey responses will be used in support of developing ASCP’s comments to CMS.
  5. Chapter and regional leadership representatives will be offered the opportunity to host local teleconferences as a platform for gathering member feedback. Local chapters and regions will be informed of available conference calls via email and the ASCP Web site.
  6. ASCP will host a dedicated non-CE education session at the 2012 ASCP Spring Conference + Exhibition in Anaheim, CA to provide a platform for member input on the consultant pharmacist independence issue and our comments.
  7. During the 60-day comment period, members can access the page for updates and resources on the LTC consultant pharmacist proposal. Members may send comments or questions to ASCP headquarters at anytime at
  8. Key ASCP employees have met and will continue to meet with a variety of stakeholders including national professional and trade associations, companies and non-government organizations.
  9. ASCP is collaborating with multiple pharmacy provider stakeholders to extract and aggregate data from consultant pharmacist software systems. The information we expect to be able to mine will include data on types of consultant pharmacist interventions and recommendations, the rate at which those recommendations are followed by prescribers, and the patient outcomes resulting from these interventions.
  10. ASCP, a member of the Pharmacy Quality Alliance (PQA), is working with PQA on a comment letter for submission to the CMS docket outlining PQA’s plan for developing quality performance measures.
  11. The Board of Directors will approve ASCP’s comments to CMS by the comment period deadline of June 11, 2012.

ASCP will continue to keep the membership informed on the progress of developing comments to CMS. Questions and comments related to this issue should be sent to

Thank you,
Vera R. Jackson, PhD
ASCP Executive Director & CEO

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