Pharmacy Associations Urge CMS to Recognize Pharmacist-Provided Services


In comments submitted to CMS, the pharmacy associations recommended removing barriers that limit pharmacists’ scope of practice.

Healthcare Policy

Several pharmacy associations, including the National Community Pharmacists Association (NCPA) and the American Society of Health-System Pharmacists (ASHP), are urging the Centers for Medicare & Medicaid Services (CMS) to recognize pharmacist-provided care services.1,2

In response to President Trump’s Executive Order (EO) on Protecting and Improving Medicare for Our Nation’s Seniors, the associations emphasized the important role that pharmacists play in patient care and outcomes when integrated into the health care team.

On October 3, 2019, President Trump signed the EO to “protect and improve Medicare by building on those aspects of the program that work well, including the market-based approaches in the current system.”3

 According to ASHP, the broad focus of the EO is on expanding access to Medicare services by reducing regulatory barriers and increasing beneficiary access and choice. This includes a provision to remove regulatory barriers that “limit professionals from practicing at the top of their profession.” However, ASHP noted that the EO language is vague, and it is unclear how it will be interpreted by Department of Health and Human Services.3

In response to the EO, CMS sought input from stakeholders on eliminating specific regulations that limit health care professionals from practicing at the top of their licenses. NCPA submitted comments to CMS and signed on to joint pharmacy comments, which included other organizations such as ASHP, American Pharmacists Association, and the National Association of Chain Drug Stores.1,2

In its submission to CMS, NCPA commended the idea put forth in the EO, and argued for recognition of the burdensome requirements that also limit pharmacists.2

“Like other medical professions, the pharmacy profession has evolved from a dispensing and product reimbursement-based industry to a profession with the training and patient relationships to provide outcomes-based services and participate in care coordination efforts,” NCPA wrote in the comments.2

NCPA urged the agency to “consider how to better incorporate highly qualified providers like pharmacists."2

To do this, NCPA offered general regulatory action recommendations:2

  • Leverage pharmacists’ expertise broadly under Medicare

  • Expand service models utilizing pharmacist-provided patent care services using CMS Innovation Center data

  • Attribute and understand the contributions of pharmacists to the health outcomes of Medicare beneficiaries

  • Implement a general supervision requirement versus direction supervision for services delivered by highly trained pharmacists

In a statement, Ronna B. Hauser, vice president of policy and government affairs operations, NCPA, said, “Community pharmacists are among American’s most accessible health care providers, seeing complex patients on average of 35 times each year. We encourage policymakers to work toward eliminating barriers that limit additional patient access to pharmacist-provided care services such as prescribing to treat strep or flu, smoking cessation and counseling services when distributing naloxone, and facilitate pharmacists’ inclusion on patient care teams in value-based delivery models.”4

In the joint comments submission, the pharmacy organizations noted, “When pharmacists partner with physicians and other health care professionals they streamline and improve outcomes, but regulations and policies that lag behind state scope of practice laws add extra barriers that limit patient access to care.”1


1. Joint Pharmacy Comments: Request for Feedback on Scope of Practice. NCPA. January 17, 2020.

2. NCPA Comments to CMS: Request for Feedback on Scope of Practice. NCPA. January 17, 2020.

3. Executive Order on Protecting and Improving Medicare for Our Nation’s Seniors [Issue Brief]. ASHP’s website. Accessed January 24, 2020.

4. NCPA Urges CMS to Recognize Pharmacist Services Beyond Dispensing [news release]. NCPA’s website. Accessed January 24, 2020.



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