Short Cycle / 14-Days-Or-Less Dispensing

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May 9, 2013

CMS released an email May 8, 2013 to Part D sponsors issuing guidance for short cycle dispensing billing. The information contained in the memo serves as a helpful reminder to LTC pharmacies required to meet short cycle dispensing requirements. The memo responds to questions from pharmacies about reporting Submission Clarification Code values on Prescription Drug Event records. The memo can be accessed here.

About Section 3310 of the Affordable Care Act

A regulation authorized by Section 3310 of the Affordable Care Act of 2010 requires certain drugs dispensed to Medicare Part D beneficiaries residing in skilled nursing facilities to be dispensed in quantities of 14 days or less.

This requirement is effective starting January 1, 2013. Here is an excerpt of the final rule (PDF), which was published in the Federal Register on April 15, 2011.

This regulation is enforced by the Centers for Medicare & Medicaid Services (CMS) and is intended to achieve cost savings by reducing the quantity of medications dispensed but not consumed by Medicare Part D beneficiaries residing in skilled nursing facilities. The cost savings realized through this provision is expected to offset the cost of other provisions in the Affordable Care Act. CMS expects this requirement to reduce the amount of prescription drug waste associated with 30-day fill cycles because of adverse reactions, care transitions, death of a patient, or other reasons.

Scope of Regulation and Requirements

The regulation covers solid brand oral dose drugs dispensed to any Medicare Part D beneficiary residing in a nursing facility from any pharmacy including closed-door, community or mail order pharmacies. Solid oral controlled substances will also be subjugated to the 14-days-or-less dispensing requirement. These drugs may be dispensed in any combination of quantities less than 14 days (e.g., 7 days, 4-3 days, 2-2-3 days, unit dose automation), but the packaging for covered drugs must be uniform throughout a single facility.

The regulation also includes reporting requirements to allow CMS to measure the effectiveness of the regulation in saving money and to track the methodologies used to comply. Part D plans will report this information to CMS, but pharmacies must use new transaction standards developed by the National Council for Prescription Drug Programs (NCPDP) to report required information to plans with claims submissions.

Please consult the following resources for additional information:

Please consult the following resources for historical information related to Short Cycle Dispensing:

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