In July 7 comments to CMS, APhA advocated to clarify regulations and remove remaining barriers to ensure all pharmacists and pharmacies, including community pharmacies, can fully implement the recent HHS testing guidance and provide all patients with accessible testing, medications, and patient care services.

APhA told CMS that pharmacists need a clear pathway for direct payment, and the same level of payment provided for other health care providers, during COVID-19—and for future public health emergencies. APhA also noted that current sample collection policies do not easily provide for reimbursement by pharmacists at the point of care by Medicare, and that the policies should be changed. We requested that this be fixed in the regulation, and that payment for these services should be the same for pharmacists as they are for physicians performing the same activity.

“Given pharmacists’ ability to reduce the $528 billion spent annually on medication-related problems, it is critical that barriers be removed so pharmacists are fully and effectively engaged as part of patient care teams,” Ilisa BG Bernstein, PharmD, JD, FAPhA, APhA senior vice president of pharmacy practice and government affairs, said in the comments.

Because APhA members told us that how CMS pays for pharmacist services in incident-to arrangements is unclear and subject to varying interpretation across the health care system, APhA also requested CMS clarify for consistency across the United States that incident-to services provided by a pharmacist can be billed at E/M codes 99212-215, in line with the services delivered.

“It is inconceivable that a pharmacist providing a 45-minute office visit to manage multiple chronic conditions and multiple medications for a complex Medicare beneficiary under an incident-to arrangement with a physician would be limited to having the service billed as a Level 1 visit (99211), that has an anticipated time commitment of 5 minutes,” noted Bernstein.

APhA also advocated for recognizing the broader range of pharmacist-provided medication management services (MMS).

We also urged CMS to use enforcement discretion to expand the  flexibilities granted to other health care providers, including broadening telehealth services by pharmacists.

APhA submitted comments on a CMS second interim final rule with comment period (IFC). The policies in the IFC were applicable beginning on March 1, 2020, or January 27, 2020, with exceptions. CMS and HHS can make additional changes for the duration of the public health emergency (PHE).

Read the July 7 APhA comments to CMS.