Friday, April 24, 2015

Pharmacists: Aren’t You Really Providers Already? Part Two

The first part of this article discussed pharmacist provider status and arguments both for and against it. Today’s post now turns to regulatory hurdles, developments towards provider status and the acknowledgment of changing roles in the pharmacist workforce.

Regulatory Hurdles
If and when they gain status as providers, pharmacists will become subject to more complex regulation. Laws such as the Anti-Kickback Statute and federal False Claims Act could create new liability for pharmacists as providers seeking fee-for-service reimbursement [1].  False Claims Act violations incur penalties of between $5,500 and $11,500 per violation, not including treble damages.
Pharmacies with large customer bases could expose themselves to unparalleled liability.  The Medicare Benefits Policy Manual also delineates specific classes of providers for purposes of reimbursement, each with its own set of conditions and requirements for billing. Provider status for pharmacists would likely receive a similar set of regulations and conditions of participation with new requirements for compliance and accreditation.

Thursday, April 23, 2015

Pharmacists: Aren’t You Really Providers Already?

While the passage of the Patient Protection and Affordable Care Act (“ACA”) ushered in a new era of access to health care, it only served to exacerbate a growing crisis in the provision of health care – lack of providers. As of April 2015, the Health Resources and Services Administration lists the population of the United States that lives within a health professional shortage area (“HPSA”) for primary care as 103,847,716, with 1,023,989 of those living in Kentucky [1].  This shortage calls for reimagining ways that non-physician providers can fill the care gap, and the debate surrounding the provider status of pharmacists with regard to federal health care programs is evidence of a changing mindset.

Tuesday, April 7, 2015

Important Recommendations from the
MedPAC March Report to Congress: Part Two

Important Recommendations from the MedPAC March Report to Congress: Part Two
Tuesday’s post discussed the recommendations of the Medicare Payment Advisory Commission (“MedPAC” or the “Commission”) with regard to fee-for-service (“FFS”) payment systems. Today’s post will discuss the Commission’s recommendations with regard to making FFS payments site-neutral, as well as its status reports on Medicare Advantage (“MA”) and the Medicare prescription drug program (“Part D”). 

Important Recommendations from the
MedPAC March Report to Congress: Part One

Each March, the Medicare Payment Advisory Commission (“MedPAC” or the “Commission”) is tasked with reporting to Congress on the current state of the Medicare fee-for-service (“FFS”) payment systems, the Medicare Advantage (“MA”) program and the Medicare prescription drug program (“Part D”).  This report gives lawmakers recommendations on ways to improve and enhance the Medicare system, as well as shore up areas of concern. This year’s report again struck at the root of systemic problems, specifically noting that an increasing issue within Medicare is a fundamental problem with FFS payment systems – the system incentivizes the delivery of more services without taking into account the value of those additional services.  Several reforms in the report are the subject of current Congressional legislation as well. In the posts for both today and Thursday, we’ll parse the various statements and recommendations in MedPAC’s March report with an eye for their effect on the workings of the system.