Today, ASHP and our partners, Academy of Managed Care Pharmacy, American College of Clinical Pharmacy, American Pharmacists Association, and American Society of Consultant Pharmacists, asked the Centers for Medicare & Medicaid Services (CMS) to remove regulatory barriers preventing patients from accessing pharmacist services. Our requests require no policy changes but will deliver immediate improvements in how pharmacists care for patients and contribute to their interprofessional care teams.
We are asking CMS to take these two steps:
- Allow physicians to bill evaluation and management (E/M) services delivered by pharmacists on the care team when provided incident-to the physician and consistent with the appropriate level of medical decision-making. Currently, pharmacist patient care services provided incident-to a physician or nonphysician practitioner can be reimbursed only at the lowest level, eliminating the ability of care teams to bill incident-to for complex services — typically reimbursed at higher levels— even though pharmacists are licensed by states to provide them.
- Make an administrative fix so pharmacists can enroll as providers in the Medicare Provider Enrollment, Chain, and Ownership System (PECOS) and obtain a Provider Transaction Access Number (PTAN). Because their pharmacists can’t enroll as providers in PECOS, Medicare patients with valid prescriptions initiated by pharmacists see their claims rejected and their care disrupted. A PTAN is necessary for internal processing and communication with Medicare when providing state-authorized services to Medicare beneficiaries, particularly those covered by Medicare Advantage.
Today’s letter is in response to a recent recognition by CMS Administrator Mehmet Oz that pharmacists should be empowered to increase patient access to care in their communities. In addition, these are actions that ASHP identified and committed to advancing at the National Academies of Sciences, Engineering, and Medicine Innovations in Pharmacy Training and Sustainable Practice to Advance Patient Care Workshop last May.
ASHP will continue efforts to increase patient access to care by recognizing pharmacists for their services in the Medicare Part B benefit. Until then, we are committed to advocating for the removal of unnecessary regulatory hurdles, including the proposals outlined today.
