CMS Proposal Threatens Independent Community Pharmacies Providing Long-Term Care Services

The Centers for Medicare and Medicaid Services' (CMS) proposal to require long-term care (LTC) facilities to contract solely with consultant pharmacists who have no affiliations to any in-facility LTC pharmacy, pharmaceutical manufacturer, or drug wholesaler could create turmoil for independent community pharmacies, particularly those in underserved, rural areas. The National Community Pharmacists Association (NCPA) has filed comments with CMS, expressing concerns that the proposal could compromise patient health and be detrimental to LTC facilities' efficiencies, continuity of care, timeliness of care, and communication between healthcare providers.

Key Takeaways:

• The NCPA is concerned that the CMS proposal could compromise patient health and create significant disruptions for independent community pharmacies providing LTC services.
• The proposal relies on insufficient data and cannot be broadly applied to the entire LTC pharmacy industry.
• The NCPA recommends that CMS exempt three groups from the requirements: rural LTC facilities, combo shops, and privately owned independent LTC pharmacies.
• A 2011 survey of NCPA members found that 80% of the LTC facilities they serve are in rural areas and that most pharmacists surveyed reported a shortage of consultant pharmacists in their communities.
• Under the proposal, LTC pharmacies would be required to dispense certain high-cost drugs in shorter, 14-day (or less) cycles, which could create havoc for LTC pharmacies and their patients.
• The NCPA represents the interests of America's community pharmacists, including the owners of more than 23,000 independent community pharmacies, who dispense nearly 40% of all retail prescriptions and employ more than 315,000 people, including 62,400 pharmacists.
• Independent community pharmacists are committed to maximizing the appropriate use of lower-cost generic drugs and reducing the estimated $290 billion wasted annually by improper medication use.

Statistics:

• The average cost per prescription dispensed increased nearly 40% for corporate-owned LTC pharmacy providers from 2004-2009, whereas the comparable figure for independent, privately owned LTC pharmacies was just 5% (Source: NCPA comments).
• 80% of the LTC facilities that NCPA members surveyed are in rural areas (Source: November 2011 NCPA survey).
• More than 315,000 people, including 62,400 pharmacists, are employed by independent community pharmacists (Source: NCPA facts).

Sources:

• National Community Pharmacists Association (NCPA)
• Centers for Medicare and Medicaid Services (CMS)
• NCPA comments filed with CMS (November 2011)
• November 2011 NCPA survey of members