American Pharmacists Association (APhA)
CMSRulemakingCMS-2016-0116

Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2017; Medicare Advantage Pricing Data Release; Medicare Advantage and Part D Medical Low Ratio Data Release; Medicare Advantage Provider Network Requirements; Expansion of Medicare Diabetes Prevention Program Model (CMS-1654-P)

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American Pharmacists Association (APhA) filings
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American Pharmacists Association (APhA) filed 1 comment on this docket between Sep 7, 2016 and Sep 7, 2016. 304 other organizations filed here. The comment window closed 3612d ago.

What American Pharmacists Association (APhA) filed (1)

Sep 7, 2016· DC--American Pharmacists Association· CMS-2016-0116-5478

APhA is pleased to submit these comments regarding the Centers for Medicare & Medicaid Services (CMS's) proposed rule regarding changes to the Medicare physician fee schedules and billing requirements for Congressional Year (CY) 2017 (the "Proposed 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, physician office practices, community health centers, managed care organizations, hospice settings, and the uniformed services. APhA supports CMS's ongoing recognition in the Proposed Rule of the significant contributions of physicians in addressing U.S. health care needs. However, physicians and other practitioners are challenged to meet the growing demand for patient care services from the eighty million aging baby boomers, insurance expansion, and the growing prevalence of chronic diseases such as diabetes and obesitythus, creating a mismatch between demand and capacity. Physician practices can greatly increase their capacity to meet patient demand if they reallocate appropriate clinical responsibilities to non-physician team members using a coordinated, team-based, patient-centered approach to care. There are over 300,000 pharmacists in the U.S., many of whom are underutilized in their capacity to contribute to addressing these unmet health care needs. Pharmacists receive doctoral-level education and training, with some pharmacists furthering their training to become specialists with board certification. Pharmacists' participation on "patient care teams" has been shown to reduce adverse drug events and improve outcomes for patients with chronic diseases. In addition, research has shown that coordinated care models involving other health care practitioners, including pharmacists, are essential for realizing the maximum impact of patient care delivery. As vital members of patient care teams, APhA strongly believes that better integration of pharmacists into Medicare is necessary as CMS continues to transition toward value-based payments. Accordingly, APhA's comments focus on the Proposed Rule's provisions that provide additional opportunities to implement policies that maximize the benefits of coordinated team-based care by promoting pharmacists' involvement in patient carea win for patients and for overall health care quality and cost. Specifically, APhA offers comments on improving patient participation in chronic care management (CCM); recognizing pharmacists as one of the primary providers of Diabetes Self-Management Training Services (DSMT); expanding the Medicare Diabetes Prevention Program (MDPP); adding medication management to assist behavioral health integration under the Psychiatric Collaborative Care Model (CoCM); aligning Accountable Care Organization (ACO) quality measures with the Quality Payment Program (QPP) measures under the Medicare Access and CHIP Reauthorization Act (MACRA); and increasing transparency by releasing Medicare Advantage (MA) bid pricing data and Part C and Part D Medical Loss Ratio (MLR) data.

Abstract

This major proposed rule addresses changes to the physician fee schedule and other Medicare Part B payment policies, such as changes to the Value Modifier, to ensure that our payment systems are updated to reflect changes in medical practice and the relative value of services, as well as changes in the statute. This proposed rule also includes proposals related to the Medicare Shared Saving Program, and the release of certain pricing data from Medicare Advantage bids and medical loss ratio reports from Medicare health and drug plans. In addition, this rule proposes to expand the Medicare Diabetes Prevention Program model

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