Note to readers from APhA Executive Vice President and CEO Tom Menighan: My friend and longtime colleague N. Lee Rucker, MSPH, is a passionate consumer advocate for increased access for seniors to medication therapy management (MTM) and an APhA Honorary Member for 2014. So I’m especially pleased to share her guest blog post with you.

First, a little background. CMS’s Center for Medicare & Medicaid Innovation (CMMI) is soliciting feedback via a Request for Information (RFI) on design of, and innovation within, several types of plans—including Medicare prescription drug plans. Stakeholders, including you, can provide input on, among other issues, MTM services in plans, as well as possible means of carving Medicare Part D plans into accountable care organizations (ACOs). Comments are due November 3, 2014. APhA is working to develop our comments and will submit them on your behalf. If you would like to provide input or to participate in comment development, please e-mail Jillanne Schulte, our Director of Regulatory Affairs.

Calling all practice innovators! If CMS knocked at your door this Halloween, would you hand them a trick, or a treat?  For example, regarding Medicare Part D’s MTM programs, would you tell CMS, “Way to go!” Or would you say, “MTM is not working out, and here’s why …” Perhaps you’ve also been thinking about:

• How your practice could work more closely with ACOs, Medicare Advantage (MA) and MA–Prescription Drug plans;
• How MTM could be an integral part of a Medicaid managed care model;
• How remote access technologies are supplementing face-to-face patient encounters.

These are not random policy questions. They are all part of CMS’s CMMI RFI on health plan innovation, which is open for comment through November 3, 2014.  As a seasoned “wonk” who spent most of the past decade tracking Part D while on staff at AARP’s Public Policy Institute, and who earlier this year wrote about the “March Madness” of Part D MTM, I would urge that whether you want to give CMS tricks or treats, just answer the door and tell them what you think!

In my book, and especially these days in the nation’s capital, brownie points are earned by asking good questions: they form the basis by which all stakeholders can engage in a thoughtful discourse. This was my modus operandi employed throughout my early years as a lobbyist, including serving on APhA’s staff more than 20 years ago; and it serves as the foundation for current work with clients of my consultancy. 

With this RFI, we should give CMS’s CMMI kudos for acknowledging that while some Part D stand-alone prescription drug plans “have demonstrated some success in promoting medication adherence and improving drug therapy through MTM programs,” CMMI is also interested in learning “whether additional flexibility would further control costs and improve quality.”

Admittedly, this is just an RFI, not a federal request-for-proposal. But today’s evolving pharmacy profession is filled with innovative practice models, amid growing frustrations with what may be unintended consequences of many federal programs. This RFI gives you an opportunity to “dish” out tricks and treats, so please gather your thoughts and share them by November 3, 2014.