The US Centers for Medicare and Medicaid Services (CMS) is accepting bids for plan participation in its Part D Enhanced Medication Therapy Management (Enhanced MTM) model.
The new model will give Medicare Part D plans more flexibility, which will help free them from CMS-imposed regulations for MTM model participation.
Mostly, the regulations identifying MTM-eligible beneficiaries will be more relaxed. Plans will also be allowed disclosure of the details of MTM involvement to beneficiaries.
In addition, the less stringent regulations will attempt to alleviate the uniformity requirement pertaining to how beneficiaries are identified.
The strategies CMS hopes to include in its Enhanced MTM model will address barriers to MTM implementation, such as the upfront cost of pharmacy involvement. The broadened targeting will also help identify more beneficiaries and improve opportunities for engagement.
The idea behind the Enhanced MTM model is essentially the same as it has always been: reduce medication-related issues and achieve savings for the Part D plan and CMS. Financial incentives will be available to participating plans in the form of prospective and performance payments.
In an effort to improve care coordination, CMS will allow prescribers more access to Medicare Part A and Part B data, which will give them a more complete picture of the patient.
Another prescriber benefit that CMS mentioned was access to up-to-date prescription records as well as a link to order a pharmacy consult. Although this point was not elaborated on, it may mean that CMS will be encouraging prescribers to entrust the pharmacist with more clinical decision-making regarding MTM.
CMS actually stated that it views pharmacists as the “point of intersection between patients and prescribers.” The agency recognized that many prescribers are not able to knit together an all-encompassing medication plan with the patient during a time-limited office visit.
In addition, CMS individually recognized pharmacists as a trusted source of patient care and information for Medicare members, doubling down on its bet that pharmacists can help patients with medication adherence and decrease medication-related adverse events.
The new Enhanced MTM model is only allowing plans to participate in 5 various regions of the country: Louisiana, Arizona, Virginia, Florida and the upper Midwest. CMS will not directly reimburse pharmacists in those 5 tested regions, but it will reimburse participating plans in the form of incentives, and Medicare Star Ratings will still be affected.
The Enhanced MTM encounter data will be analyzed using SNOMED coding systems for MTM interventions. CMS stated that it plans to include further guidance on these coding systems.
The Enhanced MTM model will allow more flexibility in the hopes that plans will become more creative in identifying patients and implementing pharmacist-led interventions.
CMS stressed that it “did not know what a quality MTM model actually looks like.” but it is opening the door for plans and pharmacies to come up with more creative ways to decrease medication-related issues and keep health care costs down.
CMS is practically begging for someone to step up to the plate and answer this call to action. The Enhanced MTM model will alleviate stringent regulations for Part D Plans in order to collect data about what works and what doesn't when it comes to MTM services.
Each individual pharmacist can begin addressing the barriers to MTM each day. By doing so, pharmacists can share ideas that will help move the profession forward and position themselves as the thought leaders of the health care industry.
Blair Thielemier, PharmD
Blair Green Thielemier, PharmD is an independent consultant pharmacist living in Arkansas with her husband and daughter. Her latest project is the first-ever virtual pharmacy conference, the Elevate Pharmacy Virtual Summit. She is also the founder of Pharmapreneur Academy, an online e-Course and Community where she guides pharmacist-entrepreneurs through the process and barriers of building a pharmacy consulting business. She is the author of How to Build a Pharmacy Consulting Business, a contributing author for Pharmacy Times and guest host on the Pharmacy Podcast. More information about Dr. Thielemier can be found on her website.