Billing for cognitive services

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TwoMoons

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I wrote this in response to an article on Politico.com. I thought I would post it here to generate discussion. I am 31 and about to graduate from pharmacy school and claim no superior knowledge of this subject...I just want to generate discussion and ideas. Thanks.



First, while pharmacists and pharmacies certainly need to be worried about reimbursement issues etc I think this issue often clouds the enormous opportunity pharmacists could offer patients, the US health care system in general, and our own profession. Community pharmacists are very accessible health care workers who, in the current dispensing model of pharmacy (IE the pharmacist's salary/wage is tied to a product) are vastly under utilized for the amount of education they receive. In general, a pharmacist's training/education includes, of course, the study of medications but also the study of diseases and disease state management. Many pharmacists even hold additional certifications that further strengthens training in areas such as diabetes management, asthma management, heart disease, etc. In other words, pharmacists can, could, and should be involved in chronic disease state management of patients. The Asheville Project, The Diabetes Ten City Challenge, and other community pharmacist led disease state management pilot programs have shown significant health benefits to patients along with reduced costs related to the disease. In other words, improved patient health and significant cost savings to payers. To be clear, the pharmacists didn't diagnose disease...that was still left to the physician and the physician is still the leader of the health care team. The pharmacists simply worked in a collaborative manner as part of the health team.



Approximately 150,000 pharmacists practice in the community setting accessible to patients. Why aren't pharmacists utilized in chronic disease state management and more involved in the health care team? Well, there are certainly many reasons. Perhaps the biggest reason is that a pharmacist cannot bill payers (IE medicare; insurance companies) for their cognitive services (ignoring MTM in Part D...I'm talking about disease state management). In the current model, the community pharmacist salary is tied to the sales of medications thus dispensing prescriptions (selling drugs) keeps the store open or investors happy. Thus, time away from dispensing is money lost in the true business sense. Doctors, nurse practitioners, PAs, clinical social workers can all bill insurance for their cognitive services. Pharmacists cannot. I can't think of another health care provider with our level knowledge and expertise that cannot bill payers for what we know or what we can/could do...


What I'm trying to get at is this: pharmacists are accessible and have the education/knowledge to participate in the health care team in a manner that helps maximize disease state management treatment while reducing costs for everyone. Research is showing this. However, a huge obstacle is being reimbursed for this activity. I don't mean this in the "me too" sense of trying to get pharmacists more money for the sake of more money. I see this as a win for patients, payers, and pharmacists.


To be clear on one more issue, I don't believe all community pharmacists are created equal. If pharmacists were ever recognized for their cognitive services in disease state management, I think the pharmacy profession would need to be tiered. In other words, in community pharmacy you could have traditional dispensing pharmacists and pharmacists that have further training (residency; board certification; etc) that would be able to bill payers.



Thanks.


PS I know there are pharmacy consultant groups that do LTC and such but I'm talking about a top-down model (IE Medicare and Third Parties reimburse) as opposed to individual contracts. Another thought I just had, if pharmacists could bill (IE generate a revenue stream for their services) you could see the mainstream development of pharmacy practice groups similar to physician groups. These practice groups could contract with clinics, LTC, etc. Anyway thanks.
 
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Did you contact your senator?
 
I have not contacted our senators personally although there is an open channel between some faculty members at the University of Montana and Max Baucas' office interested in these issues. From what I've heard, they are getting a good response from his office. This is a nice connection because, as you probably know, Baucas is probably the most powerful senator right now in terms of healthcare legislation (chair of the Finance committee).

Also, Montana is poised to join New Mexico and North Carolina in defining an advanced pharmacy practitioner which allow the state medical board to set the qualifications for this advanced practitioner (IE set the additional requirements). On it's own this bill does nothing really. But, if Medicare should allow pharmacist reimbursement for billing, Montana would be ready.
 
I have not contacted our senators personally although there is an open channel between some faculty members at the University of Montana and Max Baucas' office interested in these issues. From what I've heard, they are getting a good response from his office. This is a nice connection because, as you probably know, Baucas is probably the most powerful senator right now in terms of healthcare legislation (chair of the Finance committee).

Also, Montana is poised to join New Mexico and North Carolina in defining an advanced pharmacy practitioner which allow the state medical board to set the qualifications for this advanced practitioner (IE set the additional requirements). On it's own this bill does nothing really. But, if Medicare should allow pharmacist reimbursement for billing, Montana would be ready.

great article and good for you. I completely agree, although i think you will be hard pressed to find someone that disagrees here. Advocacy for advancement of the career should be done by everyone, although not many follow through on this. Why not send it to one of your local organizations, or get involved with it that way. Set a more formal campaign and get things going. Montana is more liberal it seems in letting that stuff into law. We are years away from allowing advanced practicing here in NYS, so consider yourself lucky.
 
A well-written response to a very important advocacy issue.

Legislators, both on the state and national levels, need to know about the services that pharmacists can provide beyond the normal scope of practice. ASHP and APhA have been consistently lobbying and trying to increase visibility of the various disease-state management programs (such as the Asheville program) for years. New practitioners and students have been raised under the pharmaceutical care model for over a decade now, and know the full scale of the benefit to the healthcare team that a properly trained pharmacist can provide.

It's more important than ever that new and future pharmacists join local, state and national organizations to advocate for the profession. Without an adequate political presence, the potentially gigantic role that pharmacists can play in the quickly changing healthcare world.

Would you happen to have a link to the original article? I'd be very interested in reading it.
 
The article on Politico basically talked about NCPA's lobbying efforts for pharmacy-based issues (mainly reimbursement issues). I support the NCPA's efforts. I just wrote a comment on the article trying to offer an additional perspective about pharmacy/pharmacist issues. I reposted it here to generate discussion. Here is the article: http://www.politico.com/news/stories/0209/18914.html
 
New member here - hi all!

I'm going to be graduating next May (if you couldn't tell by my handle, haha) and the future of pharmacy is something that I find to be very interesting.

The way I see it - we need to take this into our own hands first, establish credentials that change the narrow view of the politicians as to what a pharmacist is/does.

To do so, APha, the BoPs, someone should come up with a clinical pharmacy license; i.e. after obtaining a PharmD, candidates work under clinically trained preceptors for a predetermined number of hours in a clinical setting to obtain a separate clinical license. We already have the residency program established and this extra training should result in something tangible. Pharmacists who complete residency should receive a separate license.

This setup is similar to social work - LSW (license of social work) for those who complete the standard education and pass the board and LCSW (license of clinical social work) for those who complete supervised hours in a clinical setting. It is the LCSW that allows them to engage in therapy with patients and receive reimbursment.

I just find it hard to believe that a pharmacist who completes 2 years of formal clinical training has nothing tangible to show for it (not just the experience). If we were to set this up, I believe it would be easier to push the pharmacist reimbursment issue with government/insurance companies.

We need to take this issue into our own hands, and I think this would be a good step.
 
New member here - hi all!

I'm going to be graduating next May (if you couldn't tell by my handle, haha) and the future of pharmacy is something that I find to be very interesting.

The way I see it - we need to take this into our own hands first, establish credentials that change the narrow view of the politicians as to what a pharmacist is/does.

To do so, APha, the BoPs, someone should come up with a clinical pharmacy license; i.e. after obtaining a PharmD, candidates work under clinically trained preceptors for a predetermined number of hours in a clinical setting to obtain a separate clinical license. We already have the residency program established and this extra training should result in something tangible. Pharmacists who complete residency should receive a separate license.

This setup is similar to social work - LSW (license of social work) for those who complete the standard education and pass the board and LCSW (license of clinical social work) for those who complete supervised hours in a clinical setting. It is the LCSW that allows them to engage in therapy with patients and receive reimbursment.

I just find it hard to believe that a pharmacist who completes 2 years of formal clinical training has nothing tangible to show for it (not just the experience). If we were to set this up, I believe it would be easier to push the pharmacist reimbursment issue with government/insurance companies.

We need to take this issue into our own hands, and I think this would be a good step.

there are already specialities that exist....BCPS for example, or Board certified nuclear pharmacists, oncology, among others. The problem is the lack of jobs and positions in these fields. You ask MDs, nurses, nutritionists and any other people that work with these specialists I think that they'd agree on how vital it is to have one of these people around.
As far as why they are not as well known, I don't know if this can be attributed to a shortage in pharmacists, shortage of pharmacists wanting to pursue this, or a lack of positions that hospitals and clinical settings are willing to give to pharmacists in these fields. The answer is on the table, peoples and general knowledge to these areas is lacking and that is a hindering our ability to expand.

By the way heres the site: http://www.bpsweb.org/03_Specialties_Current.html
 
I understand that there are specialties and certifications that come with them and that's a great thing. But what I'm talking about is a license - one that recognizes a pharmacist as clinically trained and able to provide sound medical advice to a patient that should, therefore, be billable. It should not be stratified into specialties. We already have a divide between classical "dispensing" pharmacists and "clinical" pharmacists. Schools are putting a big emphasis on trying to merge the 2. The problem is, pharmacists themselves are not buying it. Some don't WANT to do clinical work - that's not what got them into the profession. Some don't WANT to work in dispensing/the administrative side. The 4 professional years give students a good foundation (I think) for both. The best thing we can do, i feel, is to recognize this.

I don't know, maybe I'm way off base here but I really think that we have the groundwork already layed for us - the residency program. Hell, we could even start establishing retail residencies (i.e. programs based on counseling patients in a retail setting). These residencies could be the requirement for the clinical license, and the clinical license could be the requirement for billing services.

I know it's not so much that we NEED these licenses to do what we're already doing - it's just that, in order for the rest of the medical community as a whole and politicians to SEE what we are already doing, we need to show it to them. I think this would help establish our clinical niche in a definite way.
 
If payers were to recognize pharmacists for their cognitive services, then a mechanism would need to be in place ensure the payers that the providers (pharmacists) are competent/able/current beyond the PharmD or RPh. I do think this model could be Board Specialization especially if the new ambulatory care specialty is approved but I'm not sure. The residency issue is certainly an avenue but then there would probably need to be an increase in residency sites. As a stated above, Montana is poised to pass into existence an advanced pharmacy practitioner which would allow the Board of Medical Examiners to set the standard for this license. That should be interesteing. I do like the idea of the Licensed Clinical Social Worker model as well (my wife is a LCSW). No matter what, in my opinion, the requirement for billing would have to have a CE component beyond the normal CE component to simply maintain licensure.
 
please see page 8 "Billing Using Incident to Physician Services"
"If the pharmacist’s services meets the incident to physician criteria, and the patient has previously been seen by a physician in the clinic, then the physician can bill for a low-level office visit (billing code 99211 on Centers for Medicare and Medicaid Service [CMS] form 1500).
Snella, et al. A Primer for Developing Pharmacist-Managed Clinics in the Outpatient Setting
Pharmacotherapy 2003;23(9):1153–1166
 
I've seen this before...the question I have is it the pharmacist billing or the physician billing? It seems like the physician bills for the service rendered by the pharmacist. It is an indirect way of recognizing cognitive services provided by pharmacists but still, ultimately, does not recognize the ability of a pharmacist to bill CMS which I think still has implications for other payers...interesting though.
 
I've seen this before...the question I have is it the pharmacist billing or the physician billing? It seems like the physician bills for the service rendered by the pharmacist. It is an indirect way of recognizing cognitive services provided by pharmacists but still, ultimately, does not recognize the ability of a pharmacist to bill CMS which I think still has implications for other payers...interesting though.
The physician is doing the billing. A pharmacist can bill Medicare Part B directly for some simple lab procedures, diabetes education if you're a certified diabetes educator, pneumo/flu shot, and durable medical equipment.
 
I love reading the young pharmacy students posts...you guys have so much hope...
 
I love reading the young pharmacy students posts...you guys have so much hope...


And I love reading the residents mocking students. :meanie:

It's almost like a blind man mocking other blind man.
 
Thanks 'bigpharmD' for your contribution to this post...your anonymous internet condescension is truly excellent...

Anyway, what do you think? Do you think pharmacists should push for cognitive service billing? As you have probably seen from the business/political side of your residency, wouldn't it be great to bill (have a positive revenue contribution) as opposed to constantly having the pharmacy department demonstrate via cost avoidance etc to the higher-ups why are clinical services are necessary? I think it would be better...anyway, condescend on sir...
 
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It would be great but I dont think it will ever happen in my lifetime. It is very hard for us druggists to prove our worth. The only way the admins let us do anything is if we prove our worth in "hard numbers." You cant just use the cliche "we save money" or "we help keep patients out of the hospital." You have to show them $$$$$.
 
Anyway, what do you think? Do you think pharmacists should push for cognitive service billing? As you have probably seen from the business/political side of your residency, wouldn't it be great to bill (have a positive revenue contribution) as opposed to constantly having the pharmacy department demonstrate via cost avoidance etc to the higher-ups why are clinical services are necessary? I think it would be better...anyway, condescend on sir...

Your logic applies to bill for services as an independent provider (physician, PA, PT etc). At an inpatient setting, the billing and reimbursement won't mean much for cognitive service provided by an employed pharmacist because of the DRG payment structure. If it was fee for service, that's a different story but that's been done away with years ago.

So it is essential to drive the "cost" down at clinical settings for clinical pharmacists. And there are more ways than "cost avoidance" to show the value of clinical pharmacy through demonstrating the lowering of hard dollars.

Now, bill for services at a retail setting for cognitive service is a feasible idea. Also, if there is a medicare reimbursement for pharmacy cognitive service, then I must be a independent provider who receives a referral from the PCP to see patients and bill for my services at both in and outpatient setting.
 
It would be great but I dont think it will ever happen in my lifetime. It is very hard for us druggists to prove our worth. The only way the admins let us do anything is if we prove our worth in "hard numbers." You cant just use the cliche "we save money" or "we help keep patients out of the hospital." You have to show them $$$$$.


Yup. You have some clue. Come work for me then we'll show you how to demonstrate the "hard dollar" savings in more than one way.
 
Now, bill for services at a retail setting for cognitive service is a feasible idea. Also, if there is a medicare reimbursement for pharmacy cognitive service, then I must be a independent provider who receives a referral from the PCP to see patients and bill for my services at both in and outpatient setting.


And my malpractice insurance will go up 10 folds or more.
 
Yup. You have some clue. Come work for me then we'll show you how to demonstrate the "hard dollar" savings in more than one way.

I'm frequently working on projects that really only potentially show type 2 and 3 savings. But they're justifiable since the risk associated is so enormous.


Posted via Mobile BlackBerry Device
 
I'm frequently working on projects that really only potentially show type 2 and 3 savings. But they're justifiable since the risk associated is so enormous.


Posted via Mobile BlackBerry Device


Bringing donuts to pharmacies as a rep does not count for frequently working on projects.
 
Wisconsin has started a program --WPQC. There are 12 pilot pharmacies involved, and as of now 4 'payors'. We basically do MTM, med rec, or level 2 interventions regarding diabetes, etc. We then bill the 'payors' and thru relay health are paid for our time. It's in the very early stages, but it is still hopeful for things to come.
 
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