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CMSRulemakingCMS-2017-0092

Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2018; Medicare Shared Savings Program Requirements; and Medicare Diabetes Prevention Program (CMS-1676-)

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American Pharmacists Association (APhA) filings
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American Pharmacists Association (APhA) filed 2 comments on this docket between Sep 11, 2017 and Sep 11, 2017. 330 other organizations filed here. The comment window closed 3242d ago.

What American Pharmacists Association (APhA) filed (2)

Sep 11, 2017· DC--American Pharmacists Association· CMS-2017-0092-1278

APhA is pleased to submit these comments regarding CMS's proposed rule "Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2018" (hereinafter, the "Proposed Rule"). (Please, refer to the attached .PDF for full comments.) APhA, founded in 1852 as the American Pharmaceutical Association, represents 64,000 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 supports CMS's ongoing recognition in the Proposed Rule of the significant contributions of physicians and other health care providers in addressing U.S. health care needs. As stated in previous APhA comments, physicians and other practitioners are challenged to meet the growing demand for patient care services from the eighty million aging baby boomers and the growing prevalence of chronic diseases such as diabetes and cardiovascular diseasethus, creating a mismatch between demand and capacity. One important mechanism physician practices can employ to greatly increase their capacity to meet patient demand is to use a coordinated, team-based, patient-centered approach to care and delegate appropriate clinical responsibilities to non-physician practitioners. 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 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 better integration of pharmacists into Medicare is necessary as CMS continues to transition toward value-based payments. Thank you for the opportunity to provide feedback on the Proposed Rule and for your consideration of our comments. As pharmacists continue to work in collaboration with our physician colleagues as vital members of patient care teams, we are happy to facilitate discussions between CMS and our members who currently provide medication management, CCM, TCM and incident-to physician services, if that would be helpful. 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. Sincerely, Thomas E. Menighan, BSPharm, MBA, ScD (Hon), FAPhA Executive Vice President and CEO cc:Stacie S. Maass, RPh, JD, Senior Vice President, Pharmacy Practice and Government Affairs Anne Burns, RPh, Vice President, Professional Affairs

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Sep 11, 2017· DC--American Pharmacists Association· CMS-2017-0092-1386

Greetings: APhA is pleased to submit these comments regarding CMS's proposed rule "Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2018" (hereinafter, the "Proposed Rule"). (Please, refer to the attached .PDF for full comments.) APhA, founded in 1852 as the American Pharmaceutical Association, represents 64,000 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 supports CMS's ongoing recognition in the Proposed Rule of the significant contributions of physicians and other health care providers in addressing U.S. health care needs. As stated in previous APhA comments, physicians and other practitioners are challenged to meet the growing demand for patient care services from the eighty million aging baby boomers and the growing prevalence of chronic diseases such as diabetes and cardiovascular diseasethus, creating a mismatch between demand and capacity. One important mechanism physician practices can employ to greatly increase their capacity to meet patient demand is to use a coordinated, team-based, patient-centered approach to care and delegate appropriate clinical responsibilities to non-physician practitioners. 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 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 better integration of pharmacists into Medicare is necessary as CMS continues to transition toward value-based payments. Thank you for the opportunity to provide feedback on the Proposed Rule and for your consideration of our comments. As pharmacists continue to work in collaboration with our physician colleagues as vital members of patient care teams, we are happy to facilitate discussions between CMS and our members who currently provide medication management, CCM, TCM and incident-to physician services, if that would be helpful. 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. Sincerely, Thomas E. Menighan, BSPharm, MBA, ScD (Hon), FAPhA Executive Vice President and CEO cc:Stacie S. Maass, RPh, JD, Senior Vice President, Pharmacy Practice and Government Affairs Anne Burns, RPh, Vice President, Professional Affairs

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Abstract

This major proposed rule addresses changes to the Medicare physician fee schedule (PFS) and other Medicare Part B payment policies.

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Co-filers (330)

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Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2018; Medicare Shared Savings Program Requirements; and Medicare Diabetes Prevention Program (CMS-1676-) (CMS) — American Pharmacists Association (APhA) | OpenPolis