The Centers for Medicare & Medicaid Services (CMS) is expected to propose rule changes for Medicare Part D sponsors that will likely require health plans to review and revise their strategies for their medication therapy management (MTM) programs and delivery of MTM services. Plan sponsors should be particularly attuned to potential changes to requirements governing comprehensive medication review (CMR), especially when such changes coincide with a rapidly growing population of eligible members.
To help you better ensure your MTM program and services meet requirements and achieve its objectives, we thought it would be helpful to answer some important questions about the comprehensive medication review. These include defining CMR (i.e., what does CMR stand for in pharmacy), how might new rules affect the delivery of CMR, and what strategies might plan sponsors consider regarding how and when CMRs are conducted?
How Is Comprehensive Medication Review Defined?
First and foremost, it’s critical for health plans to understand that the term “comprehensive medication review” (i.e., CMR) should not be used interchangeably with comprehensive medication management (CMM). Despite sounding similar, they are two distinct concepts, and understanding how they differ is essential to ensuring the proper delivery of both services.
To help differentiate the two concepts, let’s look at a definition for CMM, provided by the Patient-Centered Primary Care Collaborative (PCPCC): “[CMM is] the standard of care that ensures each patient’s medications are individually assessed to determine that each medication is appropriate for the patient, effective for the medical condition, safe given the comorbidities and other medications being taken, and able to be taken by the patient as intended. Comprehensive medication management includes an individualized care plan that achieves the intended goals of therapy with appropriate follow-up to determine actual patient outcomes. This all occurs because the patient understands, agrees with, and actively participates in the treatment regimen, thus optimizing each patient’s medication experience and clinical outcomes.”
Meanwhile, conducting the comprehensive medication review (CMR) is one of the most important facets of medication therapy management, and it is a required service to be provided to Medicare Part D beneficiaries who are eligible for MTM. Per CMS: “A CMR is a systematic process of collecting patient-specific information, assessing medication therapies to identify medication-related problems, developing a prioritized list of medication-related problems, and creating a plan to resolve them with the patient, caregiver and/or prescriber. [CMR] is designed to improve patients’ knowledge of their prescriptions, over-the-counter medications, herbal therapies and dietary supplements, identify and address problems or concerns that patients may have, and empower patients to self-manage their medications and their health conditions.”
Many elements of a CMM program overlap with CMR. Still, the National Board of Medication Therapy Management clearly draws the distinction between the concepts: “CMR incorporates elements of patient history into the creation of pharmacotherapy-based recommendations, while CMM both incorporates patient history into recommendations and makes recommendations intended to impact elements of the patient’s history through measurable clinical outcomes.”
What Is the Purpose of a Comprehensive Medication Review?
In essence, a CMR gives the clinical pharmacist or other qualified individual providing the service an opportunity to get a “full picture” of the patient’s health conditions and medication interventions. In addition to identifying potential adverse medication interactions, a CMR, as part of the MTM service, can help eligible members improve their adherence to their medication regimen, reduce bad side effects, better access their medications, and decrease what they spend on medications while facilitating better overall communication with healthcare providers.
CMRs are popular with patients, too. A recent study by the National Institutes of Health found that patients’ views of the CMR were positive, with patients finding CMR delivery valuable.
CMS requires Medicare Part D sponsors to offer a comprehensive medication review (CMR) at least once a year to eligible plan members as part of their MTM program. In 2016, CMS also added a Stars measure called "Medication Therapy Management Program Completion Rate for Comprehensive Medication Review (CMR)." This measure requires Medicare members (18-plus years old) enrolled in an MTM Program for at least 60 days to receive a CMR at any time in the reporting period.
What Does CMS Require for a Comprehensive Medication Review?
CMS expects Medicare Part D sponsors to take a more active approach to explaining the benefits of CMR to eligible beneficiaries, with the goal of increasing the number of CMRs delivered. Simply “offering” a CMR is insufficient.
Part D sponsors should actively offer CMR to newly targeted beneficiaries (that is, beneficiaries newly enrolled in the sponsor’s MTM program) as soon as possible — and no later than 60 days after enrollment. Sponsors should plan on maintaining documentation of CMR offers, including the date the offer was made and to whom the offer was delivered/communicated — regardless of whether the offer was accepted or declined.
Each CMR delivered must include an interactive, face-to-face or telehealth medication review and consultation, which must be performed by a clinical pharmacist or other qualified provider.
Furthermore, CMS expects plan sponsors to maintain documentation regarding the delivery of CMRs. Such documentation for each CMR should include who performed it, who received it, and when it was delivered, along with a dated copy of the summary.
Leveraging a Comprehensive Medication Review Template
CMS requires that CMRs include written summaries in CMS’ standardized format under §423.153(d)(1)(vii)(B) and (D). Part D sponsors should create a comprehensive medication review template to be used during the delivery of CMR to help ensure ongoing adherence to that standardized format.
Get Help Meeting Requirements for CMR and MTM
Cureatr is a leading provider of MTM program services, including comprehensive medication reviews. Proposed CMS changes could significantly increase the volume of qualified members who should receive a comprehensive medication review and MTM services.
Are you prepared for these changes? We leverage the skills of clinical pharmacists to best ensure you can keep up with new demands for compliance and member engagement. Find out how we help by booking a meeting.