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Originally Published PMPN June 2005
NEWS
Special Packaging Part of Medicare’s Plans
Will Medication Therapy Management (MTM) programs under Medicare’s Prescription Drug Benefit increase demand for compliance packaging? Possibly, given the fact that the Centers for Medicare and Medicaid Services lists “special packaging” as a service under its description of MTM. Two speakers at the annual National Symposium on Patient Compliance discussed this possibility. Sponsored by the Healthcare Compliance Packaging Council (HCPC), the event was held May 10–11 in Philadelphia.Craig Miner, Division of Drug Plan Policy, for CMS, explained the program in “CMS Perspective on the Medication Therapy Management Provisions of the Medicare Prescription Drug Benefit.” According to Miner, CMS will not directly administer the drug benefit. That will be contracted out to a number of providers. Applications for those contracts were due in March, and contracts will be announced in September.
Those entities that win contracts will have to offer some sort of MTM program. Such a program “must be designed to optimize therapeutic outcomes by improving medication use and reducing adverse drug events for targeted beneficiaries,” Miner said. Targeted beneficiaries are people who have multiple chronic diseases, need multiple drugs, and whose drugs cost at least $4000 per year (that sum will be adjusted upwards in future years). It is up to the providers to decide whether “multiple” means two, three, or more. MTM may include elements “designed to promote increased enrollee adherence to prescription medication regimens,” he said.
Special packaging is listed as an example of an MTM service, and its costs can be included as part of the dispensing fee. It is up to individual providers to design their own MTM program and determine whether special packaging will be a part of it. MTM can be offered to nontargeted beneficiaries in addition to targeted beneficiaries, with the nontargeted beneficiaries footing the bill. Initial reporting requirements are pretty basic but will be expanded as CMS gets a better sense of what it is looking for.
Anne Burns, Group Director, Practice Development and Research, American Pharmacists Association, spoke about MTM from the pharmacy’s perspective. In “Implementing Medication Therapy Management Programs in the Pharmacy,” she explained how the pharmacy folks define MTM. Such input was taken into account when Medicare defined the program. And that definition has several passages that promote adherence, which suggests a role for compliance packaging.
There will be two kinds of providers that win contracts to offer the prescription drug benefit. The first will be stand-alone prescription drug providers, many of who are pharmacy benefit managers. The second will be managed-care companies. The latter are more likely to offer comprehensive MTM programs because they already keep that kind of data, she said. The former tend to measure things only by cost.
The $4000 provision could end up denying MTM to some who need it. If enough of the drugs that someone takes are generic, the cost could come to less than $4000, but they still have complex drug regimens that could produce problems with adherence.
Burns said that any study data relevant to compliance packaging would help its cause for getting included in MTM.
Interestingly, long-term-care pharmacies (i.e., pharmacies in nursing homes) must be able to provide special packaging in order to get CMS coverage.
Even after the contracts are awarded in September, the MTM program is expected to evolve. CMS will set more-specific requirements “as we get data and see what impacts patient outcomes,” explained Miner.
The bottom line is that packaging professionals—both suppliers and purchasers—won’t be able to do any lobbying for inclusion in MTM programs until the provider contracts are awarded. Providers are expected to choose MTM features based on cost-benefit analyses.
Copyright ©2005 Pharmaceutical & Medical Packaging News
