SCPC Responds to CMS Proposed Part D Rule

DATE: April 7, 2020

Prioritize Independent Metrics for Prescription Drug Plans (PDPs) to Determine Long-Term Care (LTC) Pharmacy Payments and Appropriate Implementation of Opioid Crisis Response

Washington, DC – Commenting today on a recently-released Centers for Medicare and Medicaid Services (CMS) Proposed Rule regarding regulatory changes to key Medicare Part D provisions, the Senior Care Pharmacy Coalition (SCPC) offered policy recommendations.

President and CEO of SCPC, Alan G. Rosenbloom, pointed to two key recommendations as organization priorities requiring proper CMS implementation:

First, quality metrics that prescription drug plans (PDPs) use to evaluate and compensate long-term care (LTC) pharmacies must be developed independently. These metrics should be relevant to better outcomes for the LTC patient population and only evaluate practices within the control of LTC pharmacies that are relevant to the LTC patient population and within the control of LTC pharmacies. Rosenbloom says SCPC “strongly supports full disclosure, including public disclosure of quality measures PDPs use to evaluate and adjust payments to LTC pharmacies.”

Second, CMS must implement recent legislation Congress enacted in response to the opioid crisis as intended with respect to Part D beneficiaries living in nursing homes and other LTC facilities and settings.

Additionally, he continued, “SCPC urges CMS to add criteria PDPs must use before adopting pharmacy quality measures, including appropriate processes for metric development, independent validation of metrics, reasonable relationship between metrics and improved patient outcomes, use of metrics concerning practices within control of the pharmacy; use of metrics unrelated to financial performance of PDPs, PBMs or any pharmacies with corporate affiliations with PDPs, PBMs or any shared corporate parents, consistent application of metrics across all PDPs and metrics demonstrably relevant to the LTC patient population.”

Regarding opioid management provisions included in the Comprehensive Addiction and Recovery Act of 2016 and the within the SUPPORT for Patients and Communities Act of 2018, Rosenbloom stated: “We applaud Congressional and agency efforts to reduce and control prescription drug abuse in the Medicare Part D program. We further commend the agency for striking the appropriate balance in the Proposed Rule between this objective and the very low risk of prescription drug abuse among Part D beneficiaries residing in LTC facilities and other congregate and residential care settings.”  He noted, however, that SCPC “emphasizes the need to implement fully the statutory provisions designed to exempt Part D beneficiaries in LTC facilities from certain opioid management requirements.”

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 The Senior Care Pharmacy Coalition (SCPC) is the only national organization exclusively representing the interests of LTC pharmacies. Its members operate in all 50 states and serve 850,000 patients daily in skilled nursing and assisted living facilities across the country. Visit seniorcarepharmacies.org to learn more.