APhA has heard there’s concern about CMS’s recent Medicare Learning Network guidance requiring physicians and other eligible professionals who write prescriptions for Medicare Part D drugs or supplies to be enrolled in an approved status or to have a valid opt-out affidavit on file by a deadline in 2015. These requirements may apply only to those clinicians with independent prescribing authority for Part D drugs or supplies—a group that includes some pharmacists—but at this time, it seems that pharmacists may not be able to enroll in Medicare. APhA and other pharmacy organizations are working with CMS to find a workable solution.

Since the Part D final rule was released in May 2014, APhA has been engaged in conversations with CMS personnel and other stakeholders regarding the new requirements. CMS is fully aware that some pharmacists may be affected by the changes and is considering possible actions to safeguard Medicare beneficiary access to pharmacist care services, including allowing pharmacists to enroll in Medicare.

To allow adequate time to address outstanding issues associated with the new provision, the deadline for compliance has been extended from June 1, 2015, to December 1, 2015. CMS has requested that clinicians who have not previously enrolled in Medicare submit their applications by June 1, 2015, to allow the Medicare Administrative Contractors sufficient time to process the applications.

APhA will keep working to make sure pharmacists can continue to practice and not give up any ground in providing pharmacists’ quality patient care services. We will be updating members as new information becomes available. Given our push for provider status, the sooner CMS and other providers become accustomed to pharmacists as Medicare providers, the smoother the eventual transition will be.