The Center for Medicare and Medicaid Services (CMS) proposed regulationchange which would mandate the separation of consultant pharmacy services from the companies that provide pharmaceutical products to long-term care residents is a game changer for pharmacists. If the rule, as proposed today, is adopted by CMS, the services provided by pharmacists could no longer be bundled and bartered with the distribution and dispensing of medications. The services offered and provided by long-term care (LTC) pharmacists would stand alone, independent of the distribution of drug products.
This proposed rule change has far reaching implications for all pharmacists, not just those practicing in the long-term care arena. The conflict of interest that was exposed in the long-term care space clearly is the impetus for the proposed rules change but, as was pointed out by many in the overflow crowd attending the Town Hall Forumheld on this topic during the ASCP Annual Meeting in Phoenix earlier this month, why stop at LTC? If this conflict exists in LTC, doesn’t it exist in community pharmacy, specialty pharmacy and other settings? It clearly does but that is material for a future discussion.
The point to be made now with this proposed ruling is that if CMS is going to make this change, then pharmacists need to be recognized as care providers and compensated at a rate that will support the delivery of comprehensive medication management services to patients. This should be done for all pharmacists providing the service, regardless of where the service is delivered, and should not be limited to those practicing in LTC or any other setting. Imagine how the practice of pharmacy could change when the practice of pharmaceutical care is recognized as a reimbursable service and compensated on the merits of the value it adds to the care of patients, without conflict or without having drug product sales financially supporting the service providers. These changes are necessary to care for all those patients who could benefit from medication management services. #