SCPC provides comments on the Part D provisions of the 2023 CMS Call Letter

DATE: March 4, 2022

Dear Director Seshamani: 

The Senior Care Pharmacy Coalition (SCPC) appreciates the opportunity to comment on the Part D provisions of the 2023 CMS Call Letter entitled, “Advance Notice of Methodological Changes for Calendar Year (CY) 2023 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies” (the “Call Letter” or the “Proposal”), CMS 2022-0021. SCPC is the only Washington-based organization exclusively representing the interests of long-term care (LTC) pharmacies. SCPC’s membership includes 80% of all independent LTC pharmacies and our members serve one million residents daily in skilled nursing facilities and assisted living communities across the country.1 Given the distinct characteristics of the LTC patient population and the enhanced clinical responsibilities of LTC pharmacies, we offer unique perspectives on CMS’ initiatives and proposals, and particularly how Medicare Prescription Drug Benefit (“Part D”) policies and requirements impact the pharmacy community. 

In brief, our comments address CMS’ proposed use pharmacy quality metrics to evaluate Medicare Prescription Drug Plans (PDPs). PDPs are insurance companies not pharmacies, and their performance should be evaluated using criteria relevant to the manner in which Part D beneficiaries evaluate insurance companies providing drug coverage, not pharmacies providing prescription drugs and related services. Our comments also address CMS’ proposed use of Pharmacy Quality Alliance (PQA) pharmacy quality measures as a component of the Star Rating metrics without appropriate qualification and without metrics specific to the LTC patient population. We are concerned that the use of PQA Measures inadvertently could skew evaluation of LTC pharmacy quality, unintentionally mislead LTC patients in selecting a LTC pharmacy and unjustifiably empower Part D Plans (PDPs) and the pharmacy benefit managers (PBMs) that administer PDPs to penalize LTC pharmacies based on inaccurate quality assessments. We also are concerned that use of the proposed opioid utilization measures in determining Star Ratings for PDPs risks undermining the quality of care for LTC patients because those measures are inappropriate to the LTC patient population due to substantially different clinical needs. 

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