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5 Things to Know About CMS Medication Reconciliation Requirements

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How do you know the Centers for Medicare & Medicaid Services (CMS) takes medication reconciliation seriously? It's a topic featured in various measures within the agency's different programs and services to promote patient safety, healthcare quality, and quality improvement. Providers and payers participating in these programs and providing these services must understand CMS guidelines for medication reconciliation. Doing so will allow them to undertake better-targeted initiatives that improve medication reconciliation performance and thus improve these measures, programs, and services. Poor performance could contribute to adverse patient events, loss of reimbursement, and public-facing ratings that discourage the usage of healthcare services and enrollment in insurance plans. 

Medication Reconciliation: CMS Area of Focus 

Let's take a closer look at five things you should know about CMS medication reconciliation requirements. 

  1. Medication Reconciliation is Included in a New CMS Stars Quality Measure

Earlier in 2022, CMS announced it was adding new quality measures to its Stars program. One of the measures features medication reconciliation — specifically, medication reconciliation post-discharge (MRP). MRP, as previously defined, is the process of ensuring a patient recently discharged from the hospital has the assistance of a provider or clinical pharmacist, reviewing the medications they have been prescribed. This process guarantees they have all their expected medications, allows them to understand the purpose, appropriate frequency, and method of administration and addresses any questions or concerns. 

Prior to 2022, CMS was measuring a health plan's medication reconciliation success through a single MRP quality measure. As of 2022, CMS requires that Medicare Advantage plans report on the full Healthcare Effectiveness Data and Information Set (HEDIS®) Transitions of Care (TRC) measure. This measure will play a part in calculating 2024 Medicare Advantage star ratings.  

CMS notes, "Plans are rated on a one-to-five scale, with one star representing poor performance and five stars representing excellent performance. Star ratings are released annually and reflect the experiences of people enrolled in Medicare Advantage and Part D prescription drug plans. The star rating system supports CMS' efforts to empower people to make health care decisions that are best for them." 

Back to HEDIS® TRC. What does this have to do with CMS medication reconciliation requirements? MRP is one of the TRC measure's four reported rates. It joins "notification of a member's inpatient admission," "receipt of discharge information," and "patient engagement after inpatient discharge." One could argue that by performing proper MRP, the "patient engagement" expectation is also completed.  

As we mentioned in the following blog post, "Through its decision to move away from MRP as a standalone measure and toward the HEDIS® TRC measure, CMS seems to be placing great emphasis on the importance of transitions of care and, within them, the crucial role of medication reconciliation post-discharge."  

  1. Medication Reconciliation is a Measure for CMS's End-Stage Renal Disease Quality Incentive Program

CMS administers the End-Stage Renal Disease Quality Incentive Program (ESRD QIP). The agency notes that its purpose is to "promote high-quality services in renal dialysis facilities." The program links a portion of CMS payment for the treatment of patients who receive dialysis to facilities' performance on quality-of-care measures. Among the measures included by CMS: medication reconciliation. 

Within the CMS Measures Inventory Tool, the med rec measure is described as follows: “The percentage of patient months for which medication reconciliation was performed and documented by an eligible professional." 

The agency's rationale for including the medication reconciliation measure in ESRD QIP points to the value of the service for dialysis patients. CMS states that while medication management is a critical safety issue for all patients, those with end-stage renal disease often require ten or more medications and take an average of 17-25 doses per day. These patients also have numerous comorbid conditions, multiple healthcare providers and prescribers, and undergo frequent medication regimen changes. 

  1. Medication Reconciliation Post-Discharge is a Measure of Medicare Part C Star Rating

MRP is an active star rating measure for Medicare Part C (i.e., Medicare Advantage plans). 

This measure is submitted as three rates stratified by age group:  

  • 18-64 years of age  
  • 65 years and older  
  • All patients 18 years of age and older 

The rationale behind this measure, “Medications are often changed while a patient is hospitalized. Continuity between inpatient and ongoing care is essential."  

  1. MRP is Also a Measure for Medicare Care Compare

MRP is also one of the measures used for CMS's Care Compare (i.e., Physician Compare) initiative. This measure has the same description and rationale as MRP for the Medicare Part C star rating.  

  1. CMS Requires Medication Reconciliation for Transitional Care Management

CMS's focus on transitions of care and medication reconciliation is further evident in its coverage of transitional care management (TCM). The American Academy of Family Physicians (AAFP) notes, "Transitional care management includes services provided to a patient with medical and/or psychosocial problems requiring moderate or high-complexity medical decision making." TCM services involve a transition of care from settings that include inpatient acute care hospitals, long-term care hospitals, skilled nursing facilities, and inpatient rehabilitation facilities.  

CMS covers TCM for eligible Medicare patients. Transitional care services are provided during a 30-day period that begins when a physician discharges a Medicare patient from an inpatient stay and continues for the next 29 days. To bill Medicare for TCM, a physician or clinical staff under a physician's direction must engage in a face-to-face visit — which can include telehealth — within 14 calendar days of discharge. 

What does this have to do with medication reconciliation? CMS requires that medication reconciliation and management be provided to patients on or before the face-to-face visit date. As AAFP states, "Transitional care management medication reconciliation requires the medications on discharge to be reconciled with the medications the patient was taking previously." 

Cureatr Provides the Medication Reconciliation, and MRP Help Organizations Need 

Organizations that struggle with performing med rec and MRP consistently and properly increase their risk of failing to meet CMS medication reconciliation requirements and potentially suffering the consequences noted at the beginning of this post. Unfortunately, organizations and health plans face significant barriers to medication reconciliation and MRP success, including too many patients, too few qualified staff, too many errors, and too little time to give these critical processes the necessary attention. 

Fortunately, a solution is available that allows organizations and health plans to overcome these obstacles: Cureatr's clinical pharmacists and MRP service. The Cureatr team of clinical pharmacists, supported by advanced technology and unmatched patient data access, provide medication reconciliation, MRP, and additional medication management and care coordination services. The results? Improved patient health and satisfaction, reduced readmissions, and better-quality scores. To learn more about the Cureatr MRP service, request a consultation. 

 

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