Arrowhead Pharmacy Walter Reed - Late last week, the Centers for Medicare and Medicaid Services (CMS) made two surprising announcements. First, a press release was sent out stating that CMS would not impose provider restrictions on the administration of unfinished COVID-19 vaccine in skilled nursing facilities (SNFs), specifically referring to pharmacists. This press release was followed by a second announcement about a collaboration between CVS and Walgreens to introduce a vaccine against COVID-19 in long-term care facilities (LTCFs). This week, we'll break down these announcements, what they mean and the possible consequences they could have.
The first message is relatively short. The main purpose of this announcement is to say that CMS recognizes pharmacists as key immunization providers and that patients living in LTCFs are particularly vulnerable to COVID-19. Surprisingly, CMS underscores a key point of pharmacist efforts over the past decade that fee-for-service is necessary to increase access to certain care. With that in mind, CMS says it will "use discretionary measures" to "facilitate the effective administration of COVID-19 vaccines to SNF residents." Because pharmacists are already authorized to administer all CDC-recommended vaccines to people 3 years of age and older during a public health emergency, this opens the door for pharmacists to receive reimbursement from CMS for administering the COVID-19 vaccine to LTCF patients afterward. is happening. approved. The press release states that "CMS will allow Medicare immunization professionals, including but not limited to United States affiliated pharmacies, to directly bill and receive direct reimbursement from Medicare for immunizations of Medicare SNF residents."
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Interestingly, US partner pharmacies are specifically addressed, rather than individual practitioners such as pharmacists being singled out. This specification makes more sense when considering CVS and Walgreens' subsequent announcement of a collaboration to administer a COVID-19 vaccine to LTCF patients. This second press release features the Long-Term Care Pharmacy Partnership Program as part of Operation Warp Speed (OWS). As a reminder, OWS is the current administration's plan for the rapid distribution of a vaccine against COVID-19.
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A key point of this announcement is that LTCF pharmacists will not pay out-of-pocket to receive the COVID-19 vaccine. This is related to CMS's first announcement that they will exercise discretion to enforce provider restrictions in the LTCF to allow pharmacists to receive reimbursement from CMS. Participation in this program is not a LTCF requirement. Beginning on October 19
, LTCFs can apply to participate when a vaccine against COVID-19 becomes available. Additionally, it appears that pharmacist involvement is not limited to CVS and Walgreens employees, as a second press release states that LTCFs "may request the use of their existing pharmacy contracts to promote COVID-19 vaccinations."
These ads are a big problem for two reasons. It is not surprising that during this time of pandemic, pharmacists are seen as the primary health care providers. Pharmacists continued to lead important discussions on the delivery of vital health services throughout 2020 thanks to their expertise and high accessibility to the public. These announcements are important because they continue to highlight the importance of the support that pharmacists provide, especially when responding to public health emergencies.
However, with only two employer pharmacists (CVS and Walgreens) focusing on providing COVID-19 vaccines to LTCFs, one wonders how this limited involvement could limit patient access to this vital vaccine. One major question that may arise when considering the implementation of this policy is why CVS and Walgreens are only being discussed. We could speculate that CVS and Walgreens locations may not be available to all US LTCFs, but we prefer to let the data speak for itself. We obtained publicly available data on LTCFs available from CMS and data on current pharmacy locations available from Homeland Infrastructure Foundation-Level Data (HFILD) to create a series of maps showing where LTCFs are located in the US and where CVS and Walgreens pharmacies are located. .
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You can see that the location of LTCF is very different from where CVS and Walgreens pharmacies are located. Not surprisingly, CVS and Walgreens are primarily located in urban areas, which may result in LTCFs in rural areas having limited access to pharmacist-provided COVID-19 vaccines. To illustrate this difference, let's look at a specific example from the state of Colorado:
It can be seen that CVS and Walgreens pharmacies are located mainly in urban areas, while other pharmacies are more accessible in rural areas where additional LTCFs are located. The focus of this partnership between pharmacists and LTCF would be to open this opportunity to all pharmacists, rather than limiting it to those who work at CVS and Walgreens, to ensure that all LTCF patients receive this vital vaccine. The requirements for pharmacists other than those working at CVS or Walgreens to work with LTCF to provide the COVID-19 vaccine are unclear. If these pharmacists face obstacles after the details of this program are released, please contact the US Department of Health and Human Services, CMS, and your elected officials. As these geographic locations show, we need all pharmacists willing to provide this care, not just a select few. If you'd like to learn more about where LTCFs rank in relation to CVS and Walgreens drugstores, check out our interactive maps at the end of this article.
The second reason these messages are important is that CMS emphasized the importance of reimbursement for services and pharmacists in the joint statement. This can be considered proof that propaganda works. For years, pharmacists, students and other supporters of the pharmacy profession have shared with elected officials their concerns about the current pharmaceutical reimbursement model. The original tying of reimbursement to product has led to challenges as the profession's roles and responsibilities have evolved to focus more on the delivery of patient care services. As the sustainability of the pharmaceutical foundation business model has begun to falter in recent years, members of the profession have pushed even harder for the pharmacist business model to become more service-oriented rather than product-oriented.
While this is a small step toward only being reimbursed for providing the COVID-19 vaccine to LTCF during a public health emergency, it is a step. In this blog we have discussed the power of incremental change rather than expecting one law to do it all. What we need to do as a profession at this point is not to turn our backs on this opportunity. This is an opportunity for the pharmacist to demonstrate the therapeutic and economic value of the care we provide. Elected leaders will be watching, and how the profession responds could have a direct impact on future legislative efforts.
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