On February 5th the Centers for Medicare & Medicaid Services (CMS) issued their annual proposed rules governing Medicare Advantage and Part D prescription drug programs. This year’s proposed rule included a new idea: Medicare Advantage plans must report the performance metrics of their pharmacy networks.
By now we are likely all too familiar with the Medicare Star Ratings system – and if you’re not, consider yourself blessed. For those who are familiar, you know that this is not only a metric used to inform consumers, but Medicare Advantage plan bonus payments are tied to the quality measures that are part of the Star Rating system.
While the Star Rating system applies to both Part C and Part D plans, including different quality measures specific to the benefits provided, there is limited insight provided about the performance of a plan’s network of pharmacies. CMS proposes that beginning in 2021, Medicare Advantage plans report a list of pharmacy performance measures they utilize to evaluate their networks. CMS intends to analyze this information and publish a list of pharmacy metrics to standardize measurement across Medicare plans.
Since 2016 URAC has required our accredited specialty pharmacies to report on key performance measures started publicly releasing aggregated de-identified measure data in 2017. Our mandatory performance measures reflect critical functional elements of specialty pharmacies such as call center performance, dispensing accuracy, distribution accuracy, and prescription turn-around time. In addition, we also have measurement reporting related to drug-drug interactions and consumer experience that are not required but encouraged to better understand the quality of care and service delivery of our accredited specialty pharmacies.
Given that URAC has been at the forefront of pharmacy measurement and public reporting, we are very supportive of CMS’s efforts. While there must be some consideration given to which metrics are selected by CMS and the potential for an additional burden on plans, we believe that this is an important evolution for Medicare enrollees. Further, given the ongoing conversation about drug pricing and related expenditures on high-cost, specialty medications within Part D, we believe it is vital that CMS continue to advance Part D reporting requirements to ensure beneficiaries have access to high quality care.
All too often the vital role of pharmacists is overlooked in our health care system. We know that high-quality pharmacists and pharmacies positively impact the health of patients across the country. We believe that a published list of performance metrics is the first step to demonstrating the important impact our pharmacies have on the lives of patients across the country.
We’re looking forward to working with CMS and our partner stakeholders on this important policy development.