The news was hailed by APhA CEO and Executive Vice President Scott J. Knoer, PharmD, MS, FASHP. "This is one more example of how states are leading the way for positive change in the pharmacy profession. State pharmacy associations are out there getting the job done," he said.

He saluted the work of Arkansas Pharmacists Association CEO Jon Vinson, PharmD; Louisiana Pharmacists Association Executive Director Julie Fuselier; Maine Pharmacy Association Executive Director Amy Downing; Michigan Pharmacists Association CEO Mark Glasper; New Mexico Pharmacists Association Executive Director R. Dale Tinker; as well as each association's staff and board members.

"Their efforts to get their states' pharmacists recognized and paid for the services they provide are pushing the profession forward, and I'm grateful for all they do," Knoer said.

Quick background

• Medicaid is jointly funded by states and the federal government.
• To get their federal funding, state Medicaid plans must fulfill certain eligibility and coverage requirements.
• Individual state Medicaid programs also have flexibility in plan design. For example, coverage of physical therapy, optometry, and podiatry services are optional.
• State Medicaid programs also have the option to cover certain services delivered by OLPs, such as pharmacists.
• To receive reimbursement for such services, pharmacists must enroll as state Medicaid providers and fulfill associated requirements.

What do the SPAs do?

• Four of the five Medicaid SPAs exercise their option to cover pharmacist-provided COVID-19 services under the OLP benefit, but only during the PHE.
• Under the PREP Act, pharmacists and other pharmacy professionals already have the temporary authority to provide COVID-19 vaccines and other services; the federal authorities supersede state scopes of pharmacy practice.
• The five SPAs temporarily give them the same authorities under their Medicaid programs.
• Medicaid plans in Arkansas, Louisiana, and Maine will newly recognize pharmacists as OLPs. This recognition is pathway for Medicaid to reimburse pharmacists for clinical practices that are within their states’ scope of practice beyond the pandemic.
• Maine's SPA only applies to COVID-19 testing.
• The approved Arkansas, Louisiana, and Michigan SPAs follow CMS’s recent increase of COVID-19 vaccine administration reimbursement rates: Authorized providers, including pharmacists, will receive $40 for administering single-dose vaccines—up from $28—and $80 for administration of two-dose vaccines—up from $45. The three states’ Medicaid plans will now match Medicare’s higher reimbursement rates.
• The Michigan SPA does not explicitly extend OLP designation to pharmacists. It refers to "qualified providers," which would include pharmacists due to PREP Act authorities.
• New Mexico’s SPA allows its Medicaid plan to reimburse licensed pharmacists, state-authorized pharmacy interns, qualified pharmacy technicians, and pharmacies for the ordering and administration of COVID-19 tests and administration of COVID-19 vaccines. Payment will be determined by New Mexico Medicaid’s established pricing and rate methodology.

What happens after the PHE?

• If states want to continue paying pharmacists after the PHE, their temporary recognition as Medicaid OLPs will need to become permanent.
• CMS must approve Medicaid SPAs that propose pharmacists as permanent OLPs.
• Because CMS has already approved recognition of pharmacists as OLPs during the PHE, the agency is more likely to agree to making them OLPs permanently.
• The value pharmacists added to COVID-19 vaccination efforts is a persuasive talking point.

What does this mean for pharmacists outside of Arkansas, Louisiana, Maine, Michigan, and New Mexico?

• Other states that wish to permanently recognize and pay pharmacists under the OLP benefit can follow the five states’ lead.
• They can submit to CMS their own proposed Medicaid SPAs that, if approved, would temporarily recognize and pay pharmacists as OLPs.
• After the PHE, they can make a case to CMS that pharmacists should be permanent OLPs by demonstrating the value pharmacists added to COVID-19 vaccination efforts during the PHE.

Other considerations

• Medicaid programs are prohibited from charging their beneficiaries any amount for COVID-19 vaccination administration during the PHE and for 1 year after it ends.
• During the PHE, the federal government will pay 100% of Medicaid beneficiaries’ COVID-19 vaccine costs when they are provided by recognized providers; the approved SPAs add pharmacists to this list under the OLP benefit.
• Therefore, the federal government will pay eligible pharmacists 100% of Medicaid beneficiaries’ COVID-19 vaccine administration costs, but only during the PHE.
• The federal American Rescue Plan Act, signed by President Joe Biden on March 11, 2021, stipulates that Medicaid beneficiaries’ COVID-19 vaccine administration costs will come out of the federal government’s portion of Medicaid funding.
• In other words, states will not have to pay for Medicaid beneficiaries’ COVID-19 vaccine administration costs out of their own coffers.
• While the federal government is picking up the whole tab, pharmacists recognized as OLPs will be reimbursed $40 for each dose of COVID-19 vaccines—the same rate as Medicare immunizers.
• This isn’t permanent. The federal government will only pay 100% of Medicaid beneficiaries’ COVID-19 vaccine costs until the end of the PHE.
• After that, the federal government and the states will split the costs.