Senior Care Pharmacy Coalition (SCPC) to CMS: Development of Long Term Care (LTC)-Specific Quality Metrics Essential to Accurate Star Ratings Assessment of LTC Patient Care

DATE: March 10, 2020

Washington, DC – Commenting in detail regarding the Centers for Medicare and Medicaid Services’ (CMS) recently Proposed Rule (“Advance Notice of Methodological Changes for Calendar Year (CY) 2021 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies – Part II”), the Senior Care Pharmacy Coalition (SCPC) says developing long-term care (LTC) specific quality metrics is essential to accurately assessing LTC patient care in the Medicare Part D Star Ratings system.

SCPC President and CEO Alan G. Rosenbloom says 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 – “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.”

However, Rosenbloom says, “SCPC applauds CMS’ commitment to developing quality metrics through a stakeholder or independent organization like PQA, and to assuring that pharmacy metrics meet additional criteria to assure better patient outcomes. The agency’s commitment is reflected not only in the Advance Notice but also in recent related agency actions and proposals.”

Specifically, SCPC recommends:

• CMS should not use pharmacy quality metrics to rate prescription drug plans (PDPs);
• CMS should require PDPs to use quality metrics to evaluate pharmacies consistent with specific criteria;
• CMS should require that quality metrics applicable to the LTC patient population be specifically relevant to the LTC patient population living in LTC facilities and settings;
• CMS should evaluate opioid utilization in LTC facilities differently from the general population; and
• CMS should access antipsychotic utilization rates accurately.

Says Rosenbloom: “In conclusion, use of comparative pharmacy quality metrics to rate PDPs would provide limited meaningful information, and in some cases could be misleading for Part D beneficiaries seeking information to determine comparative quality among PDPs. Most existing pharmacy quality metrics are not specific to the LTC patient population, despite obvious differences between this population and the Medicare-eligible population living in the community. Consequently, CMS should not use pharmacy quality metrics to rate PDPs and should require that PDPs develop and implement pharmacy quality metrics that satisfy specific criteria, including the use of metrics appropriate to the LTC patient population.”

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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.