CMS response misses point of provider status
January 28, 2014
When I and nearly 40,000 Americans petitioned the White House to “recognize pharmacists as health care providers” in December 2012, we were asking for a change in “the compensation structure allowed under Medicare” so that patients would “have access to the medication expertise of pharmacists.” The response we received a few days ago to the petition from Jonathan Blum of CMS fails to address this deficiency or to indicate a willingness by CMS in writing to work with us to address the issues preventing pharmacist recognition and reasonable inclusion in care delivery models. His examples for pharmacist inclusion are limiting and miss the benefits patients receive from pharmacists’ broader patient care services. Instead, Blum restates the status quo, which we all know too well: pharmacists are the only major group of health professionals omitted as providers under the Social Security Act.
I could go on and on about this topic, but one of our members has already done so very eloquently. We’re sharing below the remarks sent by Sarah McBane of San Diego to CMS. Does this resonate with you?
Add your voice to the provider status effort! You can comment here on the blog, or access the response to the petition and click on “Tell us what you think about this response and We the People.” Together, we can do this!
Text of McBane’s letter to CMS regarding the White House petition response:
Dear Mr. Blum,
Thank you for responding to the petition regarding pharmacists and the Social Security Act. I appreciate the time taken to evaluate the petition and provide a response.
Unfortunately, the response did [not] seem to reflect any consideration of the request stated within the original petition, which was to recognize pharmacists as providers under the Social Security Act. Those of us on the frontlines of pharmacy practice know how much more pharmacists could be doing to make our health care system a better one, if only we [had] a business model and reimbursement mechanism that would facilitate this.
Instead of recognizing the possibilities inherent in the promise of pharmacists, your response reiterates the current situation, listing the health care practitioners that are recognized as providers and describing situations where pharmacists might receive reimbursement from CMS via incident-to billing or Medicare Part D. These statements lead me to believe that you did not hear and understand the essence of the petition.
Pharmacists deserve recognition as providers, not for billing and reimbursement purposes, but for our contributions to patient care. These contributions have been outlined in "Improving Patient and Health System Outcomes Through Advanced Pharmacy Practice: A Report to the U. S. Surgeon General 2011," a document that summarizes the impact pharmacists have on health care outcomes as well as cost. The report contains numerous examples of what pharmacists can do to improve care, including improving blood pressure readings, blood sugar readings for people with diabetes, and reducing the number of unscheduled health care visits. The unscheduled visits would include care delivered in the emergency department, which is very expensive and rarely effective for care of chronic conditions such as diabetes.
Pharmacists, with our extensive knowledge of medications, are essential contributors to patient care. Medications are involved in 80% of all disease treatments. Pharmacists are the only professionals whose training focuses on the safe and effective use of medications. All students who graduate from current pharmacy programs receive a doctoral degree, and many go on to complete postgraduate training in the form of a residency (similar to medical graduates). Your response to the petition lists other health care professions that are recognized as health care providers under the Social Security Act. Many of those health care professionals receive fewer hours of education and training than pharmacists, yet they are still recognized as providers. Pharmacists’ education and impact on patient care are equally valuable.
Other federal systems have recognized pharmacists as providers for decades. Veterans Affairs (VA) and the Indian Health Service (IHS) consider pharmacists as providers. Why should Medicare be any different? The population receiving care under Medicare deserves the same benefit from pharmacist-provided care as patients in the VA and IHS. Individual states—California being a notable example—have extended provider recognition to pharmacists. Individuals receiving care throughout the rest of the United States deserve access to the same care as Californians.
We pharmacists will know we have truly achieved the purposes behind the provider-status movement when pharmacists are recognized and paid for providing patient care services targeted at improved medication use and when CMS makes public policy and guidance statements that facilitate the inclusion of pharmacists within integrated care delivery models. I for one hope that you can revisit your response to the petition with these objectives in mind. In summary, I sincerely appreciate the fact that you responded to the thousands of pharmacists who signed the petition, but I feel as if you missed the point. Recognition under the Social Security Act under Title 18, Part E, Section 1861 is not simply about compensation. It is about professional recognition and quality of care. Pharmacists are integral members of the patient care team and medical home, and deserve the same recognition on a federal level as our colleagues.
Sarah McBane, PharmD, CDE, BCPS, FCCP
San Diego
Thomas E. Menighan, BSPharm, MBA, ScD (Hon), FAPhA
APhA Executive Vice President and CEO
January 28, 2014
When I and nearly 40,000 Americans petitioned the White House to “recognize pharmacists as health care providers” in December 2012, we were asking for a change in “the compensation structure allowed under Medicare” so that patients would “have access to the medication expertise of pharmacists.” The response we received a few days ago to the petition from Jonathan Blum of CMS fails to address this deficiency or to indicate a willingness by CMS in writing to work with us to address the issues preventing pharmacist recognition and reasonable inclusion in care delivery models. His examples for pharmacist inclusion are limiting and miss the benefits patients receive from pharmacists’ broader patient care services. Instead, Blum restates the status quo, which we all know too well: pharmacists are the only major group of health professionals omitted as providers under the Social Security Act.
I could go on and on about this topic, but one of our members has already done so very eloquently. We’re sharing below the remarks sent by Sarah McBane of San Diego to CMS. Does this resonate with you?
Add your voice to the provider status effort! You can comment here on the blog, or access the response to the petition and click on “Tell us what you think about this response and We the People.” Together, we can do this!
Text of McBane’s letter to CMS regarding the White House petition response:
Dear Mr. Blum,
Thank you for responding to the petition regarding pharmacists and the Social Security Act. I appreciate the time taken to evaluate the petition and provide a response.
Unfortunately, the response did [not] seem to reflect any consideration of the request stated within the original petition, which was to recognize pharmacists as providers under the Social Security Act. Those of us on the frontlines of pharmacy practice know how much more pharmacists could be doing to make our health care system a better one, if only we [had] a business model and reimbursement mechanism that would facilitate this.
Instead of recognizing the possibilities inherent in the promise of pharmacists, your response reiterates the current situation, listing the health care practitioners that are recognized as providers and describing situations where pharmacists might receive reimbursement from CMS via incident-to billing or Medicare Part D. These statements lead me to believe that you did not hear and understand the essence of the petition.
Pharmacists deserve recognition as providers, not for billing and reimbursement purposes, but for our contributions to patient care. These contributions have been outlined in "Improving Patient and Health System Outcomes Through Advanced Pharmacy Practice: A Report to the U. S. Surgeon General 2011," a document that summarizes the impact pharmacists have on health care outcomes as well as cost. The report contains numerous examples of what pharmacists can do to improve care, including improving blood pressure readings, blood sugar readings for people with diabetes, and reducing the number of unscheduled health care visits. The unscheduled visits would include care delivered in the emergency department, which is very expensive and rarely effective for care of chronic conditions such as diabetes.
Pharmacists, with our extensive knowledge of medications, are essential contributors to patient care. Medications are involved in 80% of all disease treatments. Pharmacists are the only professionals whose training focuses on the safe and effective use of medications. All students who graduate from current pharmacy programs receive a doctoral degree, and many go on to complete postgraduate training in the form of a residency (similar to medical graduates). Your response to the petition lists other health care professions that are recognized as health care providers under the Social Security Act. Many of those health care professionals receive fewer hours of education and training than pharmacists, yet they are still recognized as providers. Pharmacists’ education and impact on patient care are equally valuable.
Other federal systems have recognized pharmacists as providers for decades. Veterans Affairs (VA) and the Indian Health Service (IHS) consider pharmacists as providers. Why should Medicare be any different? The population receiving care under Medicare deserves the same benefit from pharmacist-provided care as patients in the VA and IHS. Individual states—California being a notable example—have extended provider recognition to pharmacists. Individuals receiving care throughout the rest of the United States deserve access to the same care as Californians.
We pharmacists will know we have truly achieved the purposes behind the provider-status movement when pharmacists are recognized and paid for providing patient care services targeted at improved medication use and when CMS makes public policy and guidance statements that facilitate the inclusion of pharmacists within integrated care delivery models. I for one hope that you can revisit your response to the petition with these objectives in mind. In summary, I sincerely appreciate the fact that you responded to the thousands of pharmacists who signed the petition, but I feel as if you missed the point. Recognition under the Social Security Act under Title 18, Part E, Section 1861 is not simply about compensation. It is about professional recognition and quality of care. Pharmacists are integral members of the patient care team and medical home, and deserve the same recognition on a federal level as our colleagues.
Sarah McBane, PharmD, CDE, BCPS, FCCP
San Diego
Thomas E. Menighan, BSPharm, MBA, ScD (Hon), FAPhA
APhA Executive Vice President and CEO
