American Society of Consultant Pharmacists Issues Public Comment on Centers for Medicare & Medicaid Services Proposed Rule

WASHINGTON, June 24 -- Chad Worz, CEO of the American Society of Consultant Pharmacists, Alexandria, Virginia, has issued a public comment on the Centers for Medicare and Medicaid Services' proposed rule entitled "Medicare Program: Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Value-Based Purchasing Program for Federal Fiscal Year 2021". The comment was written on June 9, 2020, and posted on June 12, 2020:

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The American Society of Consultant Pharmacists (ASCP) is the only professional society devoted to optimal medication management and improved health outcomes for all older persons in the United States and abroad. ASCP's senior care pharmacist members manage and improve quality of life for geriatric patients and other individuals residing in a variety of environments including nursing facilities, sub-acute care and assisted living facilities, psychiatric hospitals, hospice programs, and home and community-based care.

We are grateful for the opportunity to comment on this proposed rule and we will limit our comments to specific sections of the proposed rule that have special significance to the beneficiaries we serve that relate to the expertise of our profession.

Proposed SNF PPS Rate Setting Methodology and FY 2021 Update

ASCP and its members appreciate CMS' approach to the development of the Patient-Driven Payment Model. We believe that this new model has more appropriately compensated SNFs for the medical needs of nursing home residents and it has been a welcome change from the therapy-driven approach represented by the SNF resource utilization group (RUGs) model.

We have especially appreciated CMS' creation of the case-mix index for non-therapy ancillaries (NTA). We believe it is important to consider the medication needs of beneficiaries as a discreet element of the cost of care. However, as we have noted in previous comments to CMS, ASCP continues to be concerned that the NTA index does not include some of the more costly specialty medications for diseases and conditions that many SNF residents experience, such as neurologic diseases (multiple sclerosis), rheumatoid arthitis, mental health conditions, Parkinson's disease, and others. Several of these conditions have new, FDA-approved, innovative medications that have entered the market since the Accumen study that prioritized the conditions included in the NTA calculation. Residents suffering from these conditions are increasingly requiring rehabilitation in skilled nursing facilities and current PDPM reimbursement discourages SNFs from accepting individuals who are stabilized on these new treatments. Newer and expensive medications, while covered by other insurance providers, cannot be brought into the facility from the resident's home due to concerns for adulteration as well as per CMS regulation. To promote best patient care and not hinder patient access to skilled nursing beds, ASCP strongly recommends that CMS update the NTA comorbidity list to account for these types of disease states.

Furthermore, the application of specialty medications and their utility and frequency in the older adult population is not considered in this payment model. No provisions are made on how to reimburse skilled nursing homes for patients within their skilled Medicare Part A benefit that are managed on these medications which may lead to important therapies being delayed or discontinued.

ASCP would also like to express our continued concerns that the NTA index is not being adjusted as expeditiously as new therapies are arriving. Given the steady increase in the cost of prescription medication and the advances in treating diseases disproportionately affecting the elderly, we hope CMS takes this necessary issue into consideration as rate increases are considered each year.

Advancing Health Information Exchange

In the proposed rule, CMS refers to agency efforts to encourage and promote interoperable health information technology and implement the goals of the IMPACT Act and the 21st Century Cures Act. CMS recognizes the frustration PAC providers experience when technology design impedes the ability of staff to share important clinical information among different venues of care.

ASCP works closely with the Pharmacy Health Information Technology Collaborative (Collaborative) and supports the work of the collaborative. Among the issues the Collaborative have raised are:

* Lack of coordination between state prescription drug monitoring programs (PDMP): The continuing struggle to tackle the increasing medical and societal burden of the rising tide of the misuse of opioids and other drugs is being hampered when the programs intended to track dangerous drug use across state lines are not able to communicate. We agree that this issue deserves CMS' attention.

* Integration of PDMP information into the electronic health record (EHR): The Collaborative recommends the integration of PDMP information into the EHR so that clinicians would have easy access to the patient's history of use of substances of concern.

ASCP appreciates CMS' efforts to improve care of our nation's seniors in skilled nursing facilities and we offer our assistance in furthering the goal of the delivery of quality, compassionate, and cost-effective care to the frailest of our citizens.

Thank you for your attention to our concerns. We stand ready to work with CMS and other agencies to improve the quality and efficiency of the Medicare drug benefit. If you have any questions or require additional information, please contact Veronica Charles, Director of Policy and Advocacy, at vcharles@ascp.com.

Sincerely,

Chad Worz, Pharm.D., BCGP

Chief Executive Officer

American Society of Consultant Pharmacists

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The proposed rule can be viewed at: https://www.regulations.gov/document?D=CMS-2020-0036-0002

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