AMCP objects to proposed reporting requirements for Part D

February 2, 2012

The Academy of Managed Care Pharmacy is not pleased with changes to the Medicare Part D reporting requirements proposed by the Centers for Medicare and Medicaid Services.

The Academy of Managed Care Pharmacy (AMCP) is not pleased with changes to the Medicare Part D reporting requirements proposed by the Centers for Medicare and Medicaid Services (CMS).

AMCP agreed with the need for new data reporting on unused drugs and medication therapy management in long-term care (LTC), but not with the changes CMS wants to implement for contract year 2013.

The academy agreed that data needs to be collected on both generic and brand name drugs that are prescribed and dispensed but not used. The problem is that CMS has not specified how LTC pharmacies must report unused drugs to Part D sponsors. Sponsors will aggregate LTC pharmacy data and report totals to CMS.

AMCP warned that without uniform reporting standards from the National Council for Prescription Drug Programs (NCPDP), every Part D plan sponsor must create its own data collection and reporting guidelines.

“AMCP asks that CMS work with NCPDP on development of a reporting standard,” the academy wrote to CMS in response to the agency’s proposals. “Until such a standard exists, CMS must understand that the data submitted will vary between each pharmacy and each Part D plan and cannot be considered precise.”

The academy also objected that the current definitions require pharmacy staff to make assumptions about whether a prescription has been replaced or added to existing therapies in some situations. A second antipsychotic agent or a second hyperglycemic drug could mean than the existing prescription is being discontinued or that the new agent is in addition to existing therapy.

Definitions used for MTM program assessment are also imprecise and open to interpretation, AMCP said. Data elements U (drug therapy recommendations made following MTM) and V (drug therapy problem resolutions following MTM) have multiple definitions.

AMCP also objected that Element S (recipient of interactive comprehensive medication review) is being added before regulations to Medicare Advantage and Medicare Prescription Drug Benefit Programs for 2013 are finalized. Finally, the academy opposed any moves that might require Plan D sponsors to include long-term care pharmacists in MTM programs under Part D.