ASCP sees Medicare Part D as boon for consultant R.Ph.s

Consultant pharmacists can find plenty to like about Medicare Part D. The new prescription benefit that debuts next Jan. 1 is still provoking questions, but the overall impact on long-term care (LTC) pharmacy seems to be positive. "There are several very positive aspects in medication management and prescription drug plans [PDPs] for both long-term care pharmacy and long-term care pharmacists," said Tom Clark, director of policy and advocacy for the American Society of Consultant Pharmacists.

"We believe consultant pharmacists are going to be even more important under Part D than they have been in the past," Clark told a nationwide teleconference audience. "ASCP is encouraged by the broad guidance and goals set out by the Centers for Medicare & Medicaid Services. They reflect a lot of input from long-term care pharmacy."

The April teleconference is part of a series of ASCP briefings on the Medicare Modernization Act that can be replayed at http://www.scoup.net/. The society also has an updated list of resources, suggestions, and questions and answers at http://www.ascp.com/MedicareRx/

Independent pharmacies and consultant R.Ph.s can sign up for contracting by filling out the Notice of Interest in Medicare Part D Contractors form at http://www.ascp.com/MedicareRx/. LTC pharmacy chains and other provider groups should also complete the form, Clark said. When LTC providers ask CMS for pharmacy provider information to meet Part D requirements, the agency will refer only organizations or individuals that have completed the notice.

On the payment side, Part D provider rates are expected to favor LTC pharmacy over retail providers. One reason, Clark explained, is that Part D requires separate pharmacy provider networks for LTC and retail pharmacy markets. CMS has finally recognized LTC pharmacy as a distinct entity with distinct service, quality, and provider characteristics, he said. A second reason is that LTC pharmacy is specifically empowered to charge for services such as delivery and special packaging for the LTC environment.

"These are services CMS says pharmacy should get paid for," Clark said. "Long-term care pharmacy can expect to get higher fees than traditional retail pharmacy because long-term care pharmacies are providing additional services."

At the other end of the profit equation, LTC pharmacy costs may also fall. That's because LTC providers themselves will be required to provide certain pharmacy-related services, such as consultant pharmacist services, Clark explained. Pharmacy providers will no longer have to bundle those costs into drug dispensing fees.

Another significant advantage under Part D is the virtual disappearance of Medicaid. Dual eligibles, residents who are eligible for both Medicaid and Medicare, will automatically be enrolled in Part D, Clark noted. "There will essentially be no more Medicaid for long-term care," he said.

Few pharmacists will mourn the change. For R.Ph.s and pharmacies that deal with providers in more than one state, the new arrangement means they no longer have to juggle multiple state requirements. While Medicaid programs were subject to sudden changes based on state budgetary needs, Part D contracts cover at least 12 months. That puts pharmacy providers on a more predictable and more stable financial footing.

Prior-authorization requirements should also ease under Part D. Medicaid programs frequently used prior authorization to discourage utilization and reduce expenditures, Clark noted. That option will be much less attractive under Part D, he said, because PDPs must treat all Part D beneficiaries on an equal basis. Any PDP that imposes prior authorization or other requirements to limit expenditures for Medicaid-eligible patients will likely be stopped because of the discriminatory impact.

Instead of prior authorization, Clark predicted an increase in the use of tiered co-pays and other measures that are less likely to have a negative impact on pharmacy providers.