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25 December 2006

The Honorable Michael Leavitt
Secretary, Health and Human Services
U.S. Dept. of HHS
200 Independence Ave, S.W.
Washington, D.C.  20201

Dear Secretary Leavitt:

On behalf of the Montana Pharmacy Association, I am writing to express our acknowledgment of several critical issues facing healthcare, the profession of pharmacy, and appropriate drug therapy for millions of Americans and further, to ask for your leadership and consideration in constructing change to resolve these issues.  We fully appreciate the effort that this will require and we are committed to achieving success.

MEDICARE PART B The CMS-financed Institute of Medicine (IOM) reports1,2 reveal the inappropriate use, overuse, and underuse of medication leading to adverse events, medication errors, hospitalizations, and death.  This clearly illustrates a lack of effective medication therapy and management.  By optimizing medications, synergizing health care teams, avoiding drug errors, and preventing medication misadventures, clinically trained pharmacists have demonstrated the potential to save significant mortality, morbidity and billions of dollars annually.3-9

 The second IOM report2 shows that little, if any, improvement has been made since the first IOM report suggesting that without the clinical pharmacist’s involvement in patient care, minimal benefit and cost savings will be realized, thus, we argue strongly for the clinical pharmacist inclusion as providers of health care in the Medicare legislation, similar to other health care professions.

Therefore, we would request your leadership and direction for the following:

  • Legislation to obtain provider status for clinically trained pharmacists. Previous legislation (HR 4724, Congressman Burr, NC, 2004; S 974 Senator Johnson, SD,2001) failed to make it out of committee, yet this remains the most effective method to improve inappropriate medication use and minimize medication errors
  • Intimately involve physician associations and state Boards of Medical Examiners.  Clinical pharmacists would act under collaborative drug therapy agreements (CDTA) supervised by a physician or physician groups.
  • Instruct state Boards of Pharmacy to design credentialing criteria and define pharmacist scope of practice such that the Federal Government is assured appropriate billing occurs fraudulence is minimized. Currently, 41 states have redefined pharmacist scope of practice and have implemented CDTA legislation (see enclosure)
  • Instruct CMS to establish or oversee academic – established criteria (e.g., board certification, recognized advanced training, etc.)

MEDICARE PART D – MEDICATION THERAPY MANAGEMENT SERVICES (MTMS)  Many physicians currently consult or refer patients to pharmacists for our expertise to co- manage meds, minimize adverse events, and educate patients.  These services are what comprise MTMS.  We think these services are indeed unique and valuable and as such deserve compensation through public and private sources.

Therefore, we suggest the following action be taken:

  • The CMS should require that MTMS for Medicare recipients be done face-to-face with a pharmacist, with reimbursement or compensation coming directly from the CMS to the clinical pharmacist, not via prescription drug plans (PDP).
  • Dissociate the prescription – drug plan (PDP) from CMS desired MTMS and allow the pharmacist to bill directly for MTM services under their own provider number using AMA-CPT (pharmacy specific) codes, which have been developed and approved.
  • Give Medicare patients the choice from whom they receive MTMS.  Patients must trust the information they receive to ensure compliance and effectiveness.
  • Instruct the CMS to request comparative models for MTMS to ascertain the most effective and superior way to optimize drug therapy and prescription meds (e.g., local pharmacist face-to-face versus current PDP-associated MTM)
  • Ensure that all models, including the current PDP-associated MTMS, recognize pharmacists, not just pharmacies, as providers.

Respectfully,

Vince Colucci, Pharm.D., BCPS
President, Montana Pharmacy Association
Department of Pharmacy Practice
The University of Montana College of Health Professions and Biomedical Sciences
Missoula, MT 59812

cc: Senator Max Baucus, D-Montana, Chair Senate Finance Committee
      Senator John Tester, D-Montana
      Congressman Denny Rehberg, R-Montana

Enc.

References:

  1. Kohn, et al. To err is human: Building a safer health system. Washington, D.C.: Institute of Medicine 1999. web site: http://books.nap.edu/catalog/9728.html
  2. Aspden, et al. Preventing Medication Errors: Quality Chasm Series. Executive Summary. Washington, D.C.: Institute of Medicine 2006. web site: http://www.nap.edu/catalog/11623.html
  3. Schumock GT, Meed PD, Ploetz PA, Vermeulen LC. Economic evaluations of clinical pharmacy services 1988-95. Pharmacotherapy 1996; 16:1188-1208
  4. Lazarou et al. JAMA 1998; 279:1200-05
  5. Leape L, Cullen DJ Clapp MD. Pharmacist Participation on Physician Rounds and Adverse Drug Events in the Intensive Care Unit. JAMA.1999;282:267-270
  6. Montazeri M, Cook DJ. Impact of a clinical Pharmacist in a multidisciplinary intensive care unit. Crit Care Med.1994;22: 221-225.
  7. Raehl CL, Bond CA, Pitterle MS. Ambulatory Pharmacy Services Affiliated with Acute Care Hospitals. Pharmacotherapy 1993;13 (6): 618-625.
  8. Gattis WA, Hasselblad V, Whellan DJ, O'Conor CM. Reduction in Heart Failure Events by the Addition of a Clinical Pharmacist to the Heart Failure Management Team. Arch Intern Med. 1999;159:1939-1945
  9. Chiquette et al. Arch Intern Med. 1998;158:1641-47

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