CMS eases short-cycle fill rules for LTC, consultant pharmacists

May 15, 2011

CMS has eased rules on short-cycle dispensing of Part D medications in long-term-care facilities and is now requiring not 7-day but 14-day fills. The workload, however, may still double or triple.

Key Points

Pharmacists complained and the Centers for Medicare and Medicaid Services listened. The agency has eased rules on short-cyle dispensing of Part D medications in long-term-care (LTC) facilities that had raised objections from consultant pharmacists, community pharmacists, long-term-care facilities, and other stakeholders.

Instead of 7-day fills, pharmacies and facilities will be dealing with 14-day fills. Implementation has been pushed back a year to January 1, 2013. And pharmacies no longer have to take back unused medications for credit and reuse or disposal.

What hasn't changed is the planning and coordination needed to implement the change.

Memoli is also a member of the Drug Topics editorial board.

Short-cycle fill is mandated as part of the Patient Protection and Affordable Care Act. The goal of shorter fill cycles is to reduce the likelihood of pharmaceutical waste resulting from unused drugs, noted LTC pharmacist Carol Sirianni, vice president, customer programs and solutions for pharmacy wholesaler AmerisourceBergen. With only minor exceptions, Part D fills for LTC residents must be for 14 days or fewer, starting January 1, 2013.

Pharmacies will also have to collect data on drugs not used by LTC residents and report the information to Part D plans. LTC facilities and pharmacies are free to use 9-day or shorter fill cycles and Part D plans are free to incentivize fill cycles shorter than 14 days.

The move from the current 30-day fill cycle will be complicated under the best of circumstances, Sirianni said. Pharmacies can expect more fills for the same number of patients. Pharmacies must also track unused medications and report the details to Part D plans. The combination could mean more staff, more automation, more pressure, and more communication with facilities. Pharmacies, consultant pharmacists, facilities, and Part D plans must all work out the roles that each will play in creating shorter fill cycles and operating the new systems efficiently and cost-effectively.

"Pharmacy and facility collaboration will be key to the successful implementation of this new program," Sirianni said. "You can expect major changes in order processing at the pharmacy and in order handling at the facility. Contracts will have to be renegotiated and fees and copays adjusted, which adds complications to the billing process. CMS proposes that dispensing fees reflect costs, which we think are likely to increase. There will be more transactions with short-cycle fills, more time and motion at both pharmacy and facility, and more work for everyone involved."

CMS projects that dispensing fees will double under a 14-day fill cycle. But in the final rule, the agency noted that it is not at all clear whether dispensing fees must or will increase in proportion to the number of fills dispensed per month.

"I don't see fees on the table," Memoli said. "Historically, any type of compensation from any government source never goes up, it only goes down. At the same time, most of the new investment required for technology and medication returns falls on pharmacy. The positive part is that everybody is talking, pharmacies, equipment manufacturers, facilities, professional organizations."

Facilities face similar problems, added Susan Stinson, RN, AmerisourceBergen vice president, professional services, and clinical practice lead. They will have more work with shorter fill cycles and no more staff to handle the load.

"Facilities are already stressed in their medication processes," she said. "The workload will increase 2 to 3 times. What needs to happen is for long-term-care facilities to standardize and streamline their processes to free up the additional time they are going to need. There are a lot of opportunities from the logistics standpoint. Facilities and pharmacies must work together in a collaborative process."