LTC challenged by proposed Part D rules for short-cycle dispensing

February 15, 2011

Proposed rules designed to cut waste in Medicare Part D could create problems for long-term-care pharmacy.

Key Points

Proposed rules designed to cut waste in Medicare Part D could create problems for long-term-care (LTC) pharmacy. LTC facilities and pharmacies that serve them will have to adjust their care and business models for short-cycle dispensing. Most LTC facilities currently dispense 30-day fills. The proposed rules require 7-day or shorter fills for Part D prescriptions.

"The proposed rule requires LTC pharmacies to be up and running with short-cycle dispensing by January 1, 2012," said Lynne Batshon, director of policy and advocacy, American Society of Consultant Pharmacists (ASCP). "We have some concerns about pharmacies' ability to be in place within that time frame. We don't have a sense of how many pharmacies might not be able to continue to provide services."

Short-cycle dispensing is designed to reduce the waste associated with 30-day fills in the LTC setting. The Affordable Care Act of 2010 requires Part D plan sponsors to use specific, uniform dispensing techniques such as weekly, daily, or automated dose dispensing.

Tip of the iceberg

Short-cycle dispensing is only the tip of the iceberg. Not only do LTC facilities and pharmacies have to work out the mechanics of a new dispensing cycle, they also have to work out financial details with Part D plans. Without some accommodation, pharmacies could be dispensing four 7-day scripts and getting paid for one 30-day fill.

Another provision requires unused medications dispensed short-cycle to be returned to the pharmacy. Some states allow redispensing of returned medications under some circumstances; some do not, said Marissa Schlaifer, director of pharmacy affairs, Academy of Managed Care Pharmacy. The Drug Enforcement Administration restricts returns of narcotics.

Despite the conflicts, LTC facilities must return unused medications and LTC pharmacies must deal with the returns. Pharmacies must also report returns to Part D plans, which will report to CMS. Little thought has been given to the mechanics of handling returned medications, and the National Council for Prescription Drug Programs (NCPDP) is still developing the needed communication protocols.

"These are pretty significant changes," Schlaifer said. "We need a new standard for electronic communications along with all the other details. A 1-year time frame is very short."