In comments submitted to the Centers for Medicare & Medicaid Services, the Long Term Care Pharmacy Alliance expressed concerns that a proposed rule for Medicare Part C and Part D plans for short-cycle dispensing of medications in long-term care settings would cost money, not save it as intended.
Under the proposed rule, long-term care setting pharmacies would be asked to move from a 30-day fill dispensing regimen to a seven-day regimen, with the intent of saving money by lowering the amount of medication that isn't taken by patients. However, a recent study by Managed Solutions showed that any savings would be more than eliminated by quadrupling the number of dispensing fees associated with the seven-day cycle.
"While LTCPA supports the goal of reducing waste, we also recognize the need to consider all costs associated with the proposed rule, so that unintended consequences do not result from the application of the rule," said Bill Daniel, the association's executive director. "Given that it's the American taxpayer ultimately shouldering the burden of paying for this statute, it is critical that calculations such as those provided in our study be factored into the drafting of regulations."
The study, which used information from seven LTC pharmacies, found that moving all Medicare Part D prescriptions to a seven-day filling regimen would result in increased costs to plans of more than $800 million annually. Even if the seven-day fill were used only for more expensive medications, the regimen would still cost $154 million annually. The study took into account the amount of unconsumed medication in skilled nursing facilities of Medicare Part D members.
The report showed that the number of all returned solid oral prescriptions amount to 6.1 percent of all dispensed prescriptions, while the total dollar value of returned medications amounted to just 2.9 percent of the total value of all prescriptions.
Moving to a seven-day fill would result in an additional 194 million dispensings each year, the study said. Applying an average dispensing fee of $4.74 would result in a net additional cost of more than $820 million for Part D plans.
The plan did find one opportunity for savings via a seven-day dispensing regimen – in medications with ingredient costs of more than $400. Since these prescriptions represent only about 2 percent of all prescriptions filled, the estimated savings for these medications would be roughly $10 million a year.
"While it may appear that implementing a shorten-cycle dispensing regimen will necessarily generate savings in the Medicare Part D program, the analysis shows that any savings achieved by reducing unused medications are overwhelmingly exceeded by the additional dispensing fees resulting from the far greater number of prescriptions dispensed," the report concluded.
The proposed rule, Section 3310 of the Patient Protection and Affordable Care Act, was placed in the Federal Register on November 22; the comment period ended January 11.
"We believe that it was Congress' intent to decrease costs associated with unused medications for Part D residents in LTC facilities. Implementing short cycle dispensing for long-term care patients with an average length of stay of 835 days who are primarily taking maintenance medications does not meet this financial goal," said Daniel.
While the LTCPA noted that increased costs are one concern, it also filed comments with CMS indicating its belief that seven-day dispensing would also lead to access problems to LTC pharmacy services, particularly in rural and underserved communities.