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CMSRulemakingCMS-2016-0060

Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models (CMS-5517-P)

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American Pharmacists Association (APhA) filings
3

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American Pharmacists Association (APhA) filed 3 comments on this docket between Jul 11, 2016 and Dec 19, 2016. 340 other organizations filed here. The comment window closed 3508d ago.

What American Pharmacists Association (APhA) filed (3)

Dec 19, 2016· DC--American Pharmacists Association· CMS-2016-0060-4290

The American Pharmacists Association (APhA) is pleased to submit these comments (see, attached full letter) regarding the Centers for Medicare & Medicaid Services (CMSs) final rule for the Medicare Program; Merit-Based Incentive Payment System and Alternative Payment Model Incentive under the Physician Fee Schedule (PFS), and Criteria for Physician-Focused Payment Models (the Final Rule). Founded in 1852 as the American Pharmaceutical Association, APhA represents more than 62,000 pharmacists, pharmaceutical scientists, student pharmacists, pharmacy technicians, and others interested in improving medication use and advancing patient care. APhA members provide care in all practice settings, including community pharmacies, hospitals, long-term care facilities, community health centers, physician offices, ambulatory clinics, managed care organizations, hospice settings, and the uniformed services. APhA and CMS share the same goalto increase access to quality care and better health. One way to accomplish this goal would be to use CMSs regulatory flexibility to remove the barriers to allow beneficiaries to access the skills and expertise of the pharmacist, often an underutilized resource with extensive education and training, in achieving its objectives of better care for patients, improved health for communities, and lower costs. For example, CMS has already allowed lifestyle coaches, who directly furnish Medicare Diabetes Prevention Program (MDPP) services, to receive National Provider Identifiers (NPIs) and reimbursements through MDPP suppliers in the final PFS rule. Like pharmacists, lifestyles coaches are also not recognized as eligible professionals under 1848(k)(3)(B) or practitioners under 1842(b)(18)(C) of the Social Security Act. While APhA supports this type of regulatory approach to increase the availability of and patients access to services like those within the MDPP, additional regulatory changes to allow for increased pharmacists participation as part of a coordinated approach would also be incredibly impactful. The current MDPP model provides federal funding to YMCAs, however, these facilities are not available in every community. In contrast, nearly 91% of Americans live within five miles of a community pharmacy, and the inclusion of pharmacists as part of patients health care teams can have a profound impact on access, quality, health outcomes and costs, particularly in medically underserved communities. Accordingly, CMS should establish similar mechanisms in future rule-making to appropriately expand the type of practitioner eligible and attribute the role that pharmacist services and pharmacists play in improving care under the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative payment models (APMs) Thank you for the opportunity to provide feedback on the Final Rule and for your consideration of our comments. We continue to encourage CMS to use pharmacists in new payment and delivery mechanisms to improve the quality of care provided to Medicare beneficiaries. If you have any questions or require additional information, please contact, Michael Baxter, Director of Regulatory Affairs, at mbaxter@aphanet.org or by phone at (202) 429-7538.

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Jul 11, 2016· DC--American Pharmacists Association (And Other Pharmacist Organizations)· CMS-2016-0060-3397

The undersigned pharmacy organizations would like to thank the Centers for Medicare and Medicaid Services ("CMS") for the opportunity to comment on the Proposed Rule for the Medicare Program; Merit-Based Incentive Payment System and Alternative Payment Model Incentive under the Physician Fee Schedule ("PFS"), and Criteria for Physician-Focused Payment Models (the "Proposed Rule"). Collectively, our organizations represent over 100,000 pharmacists across the full spectrum of practice settings. To align with CMS's transition to value-based payments, our comments focus on removing barriers to pharmacist participation in Medicare; recognizing pharmacists and other health care providers' contributions in quality and clinical practice improvement activity ("CPIA") performance measurement; urging CMS to include or support the inclusion of pharmacist representation on the PTAC and in prioritization of new PFPMs; and improving clinical information exchange between pharmacists and physicians and other health care practitioners. Sincerely, Thomas E. Menighan, BSPharm, MBA,Lucinda L. Maine, Ph.D., R.Ph. ScD (Hon), FAPhAExecutive Vice President and CEO Executive Vice President and CEOAmerican Association of Colleges American Pharmacists Associationof Pharmacy Arnold E. Clayman, PD, FASCPSusan A. Cantrell, R.Ph., CAE Vice President, Pharmacy Practice &Chief Executive Officer Government AffairsAcademy of Managed Care Pharmacy American Society of Consultant Pharmacists Jillanne M. Schulte, JDBrenda Schimenti Director, Federal Regulatory AffairsExecutive Director American Society of Health-SystemCollege of Psychiatric and PharmacistsNeurologic Pharmacists (CPNP) David G. Miller, R.Ph.Rebecca P. Snead, R.Ph. Executive Vice President and CEOExecutive Vice President and CEO International Academy of CompoundingNational Alliance of State PharmacistsPharmacy Associations Ronna Hauser, Pharm.D. Vice President, Policy & Regulatory Affairs National Community Pharmacists Association

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Jul 11, 2016· DC--American Pharmacists Association (And Other Pharmacist Organizations)· CMS-2016-0060-3474

The undersigned pharmacy organizations would like to thank the Centers for Medicare and Medicaid Services ("CMS") for the opportunity to comment on the Proposed Rule for the Medicare Program; Merit-Based Incentive Payment System and Alternative Payment Model Incentive under the Physician Fee Schedule ("PFS"), and Criteria for Physician-Focused Payment Models (the "Proposed Rule"). Collectively, our organizations represent over 100,000 pharmacists across the full spectrum of practice settings. To align with CMS's transition to value-based payments, our comments focus on removing barriers to pharmacist participation in Medicare; recognizing pharmacists and other health care providers' contributions in quality and clinical practice improvement activity ("CPIA") performance measurement; urging CMS to include or support the inclusion of pharmacist representation on the PTAC and in prioritization of new PFPMs; and improving clinical information exchange between pharmacists and physicians and other health care practitioners. Sincerely, Thomas E. Menighan, BSPharm, MBA,Lucinda L. Maine, Ph.D., R.Ph. ScD (Hon), FAPhAExecutive Vice President and CEO Executive Vice President and CEOAmerican Association of Colleges American Pharmacists Associationof Pharmacy Arnold E. Clayman, PD, FASCPSusan A. Cantrell, R.Ph., CAE Vice President, Pharmacy Practice &Chief Executive Officer Government AffairsAcademy of Managed Care Pharmacy American Society of Consultant Pharmacists Jillanne M. Schulte, JDBrenda Schimenti Director, Federal Regulatory AffairsExecutive Director American Society of Health-SystemCollege of Psychiatric and PharmacistsNeurologic Pharmacists (CPNP) John Voliva, R.Ph.Rebecca P. Snead, R.Ph. Executive Vice PresidentExecutive Vice President and CEO International Academy of CompoundingNational Alliance of State PharmacistsPharmacy Associations Ronna Hauser, Pharm.D. Vice President, Policy & Regulatory Affairs National Community Pharmacists Association

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Abstract

Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) repeals the Medicare sustainable growth rate (SGR) methodology for updates to the physician fee schedule (PFS) and replaces it with a new Merit-based Incentive Payment System (MIPS) for MIPS eligible clinicians or groups under the PFS. This proposed rule would establish the MIPS, a new program for certain Medicare-enrolled practitioners. MIPS would consolidate components of three existing programs, the Physician Quality Reporting System (PQRS), the Physician Valuebased Payment Modifier (VM), and the Medicare Electronic Health Record (EHR) Incentive Program for Eligible Professionals (EPs), and would continue the focus on quality, resource use, and use of certified EHR technology (CEHRT) in a cohesive program that avoids redundancies. This proposed rule also would establish incentives for participation in certain alternative payment models (APMs) and includes proposed criteria for use by the Physician-Focused Payment Model Technical Advisory Committee (PTAC) in making comments and recommendations on physician-focused payment models. In this proposed rule we have rebranded key terminology based on feedback from stakeholders, with the goal of selecting terms that would be more easily identified and understood by our stakeholders.

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Co-filers (340)

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Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models (CMS-5517-P) (CMS) — American Pharmacists Association (APhA) | OpenPolis