CMS Reverses Course on Independent Consulting Pharmacists

In a move that most industry watchers including myself believed was unlikely to occur, CMS decided to reverse course on a proposal to require SNFs to have separate relationships for dispensing and consulting pharmacies/pharmacists.  CMS publicized its decision yesterday.

About a month ago in a post I wrote regarding post-acute trends ( ), I indicated that my sources inside D.C. and CMS were all but certain that a final rule implementing the required separation as of January 2013 was forthcoming.  In calls today, the prevailing news is that via the comment period and protracted industry pressure, CMS realized it needed to move away from this position.  Perhaps more telling to “what” transpired is the directed two-tone sound flooding CMS.  The first loud and repetitive sound drilled throughout CMS their inherently flawed and unsupported conclusion that the pharmacy relationships correlated directly to increases in antipsychotics and psychotropic drug regimes found in SNFs.  As I mentioned in my earlier post, this conclusion was supported by no clinical or valid data. In short, from all clinical segments tied to the industry, CMS was bombarded with data refuting this assumption and demands to demonstrate this preposterous correlation.   The second deafening sound regarded the financial implications for facilities, already stinging from significant Medicare cuts and insufficient Medicaid reimbursement.  In my case, I provided directly, supporting financial and operating data for certain industry client groups illustrating the improbability of sourcing independent consultants, the costs that would be incurred to employ or engage an independent consultant, and the tangential costs the facility would bear in terms of software investment, time, and other resource utilization to implement “effectively” such a system.

The frank reality is that CMS wholly missed the mark initially.  There is a clear shortage of pharmacists nationally and thus, a real acute shortage in certain regions and rural locations.  There is a pronounced shortage of clinical expertise and geriatric pharmacologists, the back-bone of good consulting.  Finally, only organizations sufficient in size and mass have made the necessary software and system investments to make consulting effective and efficient; most other organizations remaining lax in the tools necessary to undertake SNF clients on a consulting pharmacology engagement.

Finally a win for the an industry segment that has really taken hits from a regulatory and reimbursement prospective.  SNFs needed this reprieve, if for no other reason than to continue to digest all of the other oft ill-conceived and illogical requirements already on their plates.

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