ASCP President comments to CMS Response

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I have spent the last few days wading through the Centers for Medicare & Medicaid Services’ (CMS) response to public comments on consultant pharmacist independence. Based on what I have read, I believe ASCP has been given a prime opportunity to take the lead on addressing very strong and disconcerting comments about the value of consultant pharmacists’ services. We must get out front and lead this charge! There is common ground with other LTC stakeholders on this issue and we will work with them to gather the data necessary to respond to CMS’s concerns. I also look forward to the opportunity to develop industry-wide quality measures through collaboration with quality standards organizations, such as the Pharmacy Quality Alliance (PQA).

In reaction to CMS’s response, some are saying we dodged a bullet. I don't see CMS’s response in this light. I think their response is perhaps a warning to turn things around or face more regulations down the road!

Below you will find a summary of what CMS said in its response to public comments and ASCP’s corresponding Action Steps. I hope you will join me in actively engaging in advocating for our profession and our patients.

Sincerely,
Penny Shelton, PharmD, CGP, FASCP
ASCP President

Summary of CMS Response on Consultant Pharmacist Independence

CMS has decided not to finalize a requirement for consultant pharmacists to be independent from LTC pharmacies, pharmaceutical manufacturers, distributors or their affiliates at this time. However CMS remains convinced that problems associated with conflicts of interest persist throughout the LTC setting, and that broader changes beyond consultant pharmacist independence are necessary in order to ensure patient safety and quality of care. CMS expects the full LTC industry to immediately take steps to improve transparency and reduce the prevalence of unnecessary drugs and drug overutilization in nursing facilities, particularly with respect to off-label use of atypical antipsychotics. CMS plans to implement requirements for nursing facilities to prevent problems associated with conflicts of interest in a future notice and comment rulemaking. In the interim, CMS solicits additional feedback from the public through a series of questions. Public comments are due 60 days from the date of publication in the Federal Register.

To see all the information, visit the LTC Rule page.

ASCP’s Action Steps

  1. ASCP sent an e-blast on the evening of April 2 alerting members about CMS's response to public comments.
  2. ASCP prepared a summary analysis of CMS's response to public comments for distribution to members on April 5.
  3. ASCP focused on the CMS response to public comments during its Policy & Advocacy Monthly Briefing - April 5 at 1:00 PM EDT.
  4. ASCP is organizing a process for submitting written comments for the 60-day review and comment period.
  5. ASCP is seeking clarification on definitions of some terms in the CMS response.
  6. ASCP is considering offering revised definitions for some terms in the CMS response.
  7. ASCP has begun follow up with AMDA and other national organizations representing nursing facilities to discuss the impact of the CMS response on medical directors/prescribers.
  8. ASCP will work with the Pharmacy Quality Alliance (PQA) to identify collaborative opportunities for the development of drug regimen review quality measures.
  9. ASCP will seek input from members at Spring Conference 2012 and provide members with updates at the meeting.
  10. ASCP will research current data that demonstrates MRR effectiveness on cost savings, improved outcomes, and reduced medication-related hospitalizations.
  11. ASCP will continue to dialogue with CMS on issues regarding transparency, quality measures, and the value of consultant pharmacists.
  12. ASCP will continue to provide updates to our members on all developments.

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