On January 12, URAC submitted comments in response to the Centers for Medicare and Medicaid Services’ (CMS) proposed rule for Medicare Advantage for 2019. As part of the proposed rule, CMS requests feedback regarding the role that accreditation, namely accreditation of specialty pharmacies, plays in Part D. CMS noted anecdotal concerns that have been reported regarding the potential limiting nature of Part D contracts that require pharmacies to maintain Specialty Pharmacy Accreditation.
As patients have relied on an increasing number of specialty drugs for their care, payers, employers, and their contracted PBMs have focused on the elevated risks associated with these complex medications and disease states. While the short-term impact of these management efforts on access must be monitored, the importance of quality management as it relates to patient safety and outcomes must not be overlooked.
As detailed in our comments, URAC urges CMS to take an active role in this debate as we fear Medicare is at risk of falling behind nationally accepted principles of pharmacy management. While we understand CMS’s decision not to define a “specialty pharmacy” for fear of an undue influence on the market, we would note that there are broadly accepted, established principles of quality upon which CMS can engage to ensure Medicare enrollees are afforded the same level of quality care as commercially insured patients.
URAC’s comments to CMS reject suggestions that the value of accreditation as a quality assurance tool is dependent on the nature of Part D contracts. Regardless of how Part D sponsors build their networks, the value of accreditation does not change in that it is always a validator of quality uniquely focused on the skills and services required to appropriately care for patients.
CMS indicated in the proposed rule that it had received complaints from pharmacies that Part D sponsors have begun to require accreditation by multiple accrediting organizations. URAC indicated that it believes accreditation is an important independent validator of an organization’s quality. However, URAC does not support redundant requirements that increase the administrative burden pharmacies face. We believe, where there is substantial similarity among accreditors, one accreditation is sufficient to demonstrate an organization’s quality. Therefore, we view any requirement for URAC Specialty Pharmacy Accreditation coupled with an additional accreditation from another entity to be an unnecessary and redundant burden on pharmacies.
Read URAC’s comment letter to CMS here.