By Kate H. Gamble, Senior Editor
In comments submitted to the U.S. Centers for Medicare and Medicaid Services (CMS) about its proposed rule for Accountable Care Organizations (ACOs) and the Medicare Shared Savings Program (MSSP), the National Community Pharmacists Association (NCPA) is seeking changes and clarifications on several critical points.
“Accountable Care Organizations have the potential to improve health outcomes and ultimately reduce costs through more coordinated care if structured properly,” said NCPA Executive Vice President and CEO B. Douglas Hoey, RPh, MBA, in a statement
. “However, those outcomes will be more likely if community pharmacists, with their proven expertise and services, are included in a robust manner. By better incorporating pharmacists, patients and taxpayers will benefit. The rulemaking process for ACOs must focus on removing logistical and financial impediments that could limit pharmacist participation or hinder the ability of all health care providers to accurately document the successes that should follow.”
NCPA’s comments included the following points:
There is a need to address concerns that ACOs might fail to capitalize on the value offered by pharmacists and pharmacies unless their inclusion in ACOs is explicitly authorized by CMS.
In order to facilitate Medication Therapy Management servicess (MTM), CMS should establish mechanisms to help ACOs determine where to allocate resources in advance or adopt a prospective patient assignment system so that the resources are targeted appropriately.
All ACO providers/suppliers should be required to provide patients with specific and clear notification information, so that patients who opt out of an ACO may continue to go to their pharmacy of choice, whether or not it is contracted with that ACO.
CMS must develop a privacy liability safe harbor mechanism whereby ACO participant pharmacists can receive protected health information regarding potential ACO beneficiaries without inadvertently running afoul of privacy laws.
CMS should aid the incorporation of quality measures that encourage ACOs to focus on appropriate management of prescription drug therapy and as part of a successful disease management protocol.
“NCPA strongly urges CMS to expressly provide that ACOs be authorized to pay for and share savings with ACO participant community pharmacists for certain services that they provide outside of Part B fee-for-service services, especially MTM and disease management services,” the letter stated
. “Substantial evidence exists to demonstrate that pharmacists provide valuable preventive services, such as DSMT and MTM, which decrease health care expenditures for Medicare beneficiaries and improve the quality of the health care outcomes for those beneficiaries.”
The letter cited a position statement from the American Diabetes Association which noted that multiple studies support the fact that diabetes self-management education “is associated with improved diabetes knowledge and improved self-care behavior, improved clinical outcomes such as lower A1C, lower self-reported weight, improved quality of life, healthy coping, and lower costs.” The ADA also cited studies finding that “diabetes education is associated with increased use of primary and preventive services and lower use of acute, inpatient hospital services. Patients who participate in diabetes education are more likely to follow best practice treatment recommendations, particularly among the Medicare population, and have lower Medicare and commercial claim costs.”